American New Covenant Church v. Commissioner
United States Tax Court
On Oct. 18, 1976, Life Science Church, Chapter 669 (L.S.C.), submitted an application together with its charter and supporting documentation to respondent seeking exempt status under sec. 501(c)(3), I.R.C. 1954. L.S.C. was an unincorporated auxiliary church chartered on Dec. 30, 1975, by Life Science Church, an affiliate of the Basic Bible Church of Minnesota; under the terms of its charter, it could not incorporate or form other churches, and its members were bound to…
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On Oct. 18, 1976, Life Science Church, Chapter 669 (L.S.C.), submitted an application together with its charter and supporting documentation to respondent seeking exempt status under sec. 501(c)(3), I.R.C. 1954. L.S.C. was an unincorporated auxiliary church chartered on Dec. 30, 1975, by Life Science Church, an affiliate of the Basic Bible Church of Minnesota; under the terms of its charter, it could not incorporate or form other churches, and its members were bound to support the principles of Life Science Church. Petitioner's attorney informed the Internal Revenue Service in September of…
1Opinion of the Court
OPINION
Dawson, Judge:
This case was assigned to Special Trial Judge Francis J. Cantrel for the purpose of conducting the hearing and ruling on respondent’s motion to dismiss for lack of jurisdiction. After a review of the record, we agree with and adopt his opinion which is set forth below.1
OPINION OF THE SPECIAL TRIAL JUDGE
Cantrel, Special Trial Judge:
Petitioner, challenging an adverse determination issued by respondent, attempts to invoke the jurisdiction of this Court pursuant to section 7428,2 for a declaratory judgment that it is entitled to exemption from Federal income taxes under…
2Cases cited6 opinions
- Simon v. Eastern Kentucky Welfare Rights OrganizationSupreme Court of the United States · 1976
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Trustees of Dartmouth College v. WoodwardSupreme Court of the United States · 1819
- Houston Lawyer Referral Service, Inc. v. CommissionerUnited States Tax Court · 1978
- Bolger v. CommissionerUnited States Tax Court · 1973
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3Cited by15 opinions
- Gladstone Foundation v. CommissionerUnited States Tax Court · 1981
- Friends of Soc. of Servants of God v. CommissionerUnited States Tax Court · 1980
- Loftus v. CommissionerUnited States Tax Court · 1988
- New Dynamics Foundation v. United StatesUnited States Court of Federal Claims · 2006
- New York State Teamsters Conference Pension & Retirement Fund v. CommissionerUnited States Tax Court · 1988
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