Spiritual Outreach Society v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
1Opinion of the Court
HENLEY, Senior Circuit Judge.
Spiritual Outreach Society (SOS) appeals the tax court’s decision denying its claim for status as a church under I.R.C. §§ 509(a)(1) and 170(b)(l)(A)(i) (1990). 1 Spiritual Outreach Society v. Commissioner, Tax Ct.Mem.Dec. (CCH) 1990-41 (1990). On appeal, SOS contends that the tax court erred when it found that SOS neither fulfilled an associational role required of churches nor satisfied the listed requirements used by the IRS to determine church status. We affirm.
FACTS
The case was submitted to the tax court on a stipulated record. Accordingly, our discussion of…
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