General Conference of Free Church v. Commissioner
United States Tax Court
Action for declaratory judgment under sec. 7428(a), I.R.C. 1954. Petitioner received a final adverse determination from the respondent stating that its organizing document neither limited its purposes nor its distribution of assets upon dissolution as required under sec. 501(c)(3) and that petitioner failed to describe its activities and purposes in sufficient detail.
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Action for declaratory judgment under sec. 7428(a), I.R.C. 1954. Petitioner received a final adverse determination from the respondent stating that its organizing document neither limited its purposes nor its distribution of assets upon dissolution as required under sec. 501(c)(3) and that petitioner failed to describe its activities and purposes in sufficient detail. Held, on the facts established by the administrative record and assumed to be true, petitioner was not organized and operated exclusively for religious purposes and thus is not qualified for exemption from taxation pursuant to…
1Opinion of the Court
OPINION
Forrester, Judge:
This is an action for declaratory judgment pursuant to section 7428(a).1 Petitioner General Conference of the Free Church of America, filed Form 1023, an Application for Recognition of Exemption, on December 21, 1976, with the District Director, Chicago, Ill. Therein, petitioner requested that an administrative determination be made that its organization qualified for exemption from Federal income taxation under section 501(c)(3).
On January 17, 1978, respondent issued a final adverse determination letter which denied petitioner’s exemption. Respondent determined that…
2Cases cited17 opinions
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3Cited by55 opinions
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