Legal Opinion

Oakknoll v. Commissioner

United States Tax Court

Decided February 23, 1978No. Docket No. 2192-75PublishedCited by 37 opinions

Petitioners formed a religious organization and took deductions for contributions made to it. Held: Petitioners have not carried their burden of proof to show the organization was operated exclusively for religious purposes no part of the net earnings of which would inure to the benefit of any private shareholder or individual. As a result, any deductions taken for contributions made to such organization must be disallowed.

1Opinion of the Court

Irwin, Judge:

Respondent determined deficiencies in petitioners’ income taxes for the calendar years 1971 and 1972 in the amounts of $1,522.14 and $694.06, respectively.

After a concession by petitioners, the only issue which remains for our decision is whether petitioners are entitled to deductions for contributions made to the Religious Society of Families.

FINDINGS OF FACT

Petitioners Calvin K. and Mary I. of Oakknoll, husband and wife, were legal residents of Frewsburg, N.Y., at the time of filing their petition herein. Although it is not clear from the record where they filed their returns…

2Cases cited1 opinion

  1. Morey v. RiddellDistrict Court, S.D. California · 1962

3Cited by37 opinions

  1. Stephenson v. CommissionerUnited States Tax Court · 1982
  2. John L. Stephenson v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1984
  3. Davis v. CommissionerUnited States Tax Court · 1983
  4. General Conference of Free Church v. CommissionerUnited States Tax Court · 1979
  5. Bethel Conservative Mennonite Church v. CommissionerUnited States Tax Court · 1983

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