Legal Opinion

The Church of Eternal Life & Liberty, Inc. v. Commissioner

United States Tax Court

Decided April 29, 1986No. Docket No. 27487-82XPublishedCited by 21 opinions

P claims to be a church exempt from Federal income taxation under sec. 501(a), I.R.C. 1954, and which is not required to file a Form 1023, Application for Recognition of Exemption.

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P claims to be a church exempt from Federal income taxation under sec. 501(a), I.R.C. 1954, and which is not required to file a Form 1023, Application for Recognition of Exemption. During the period before the Court, Oct. 1, 1976, through Sept. 1, 1982, P received a significant percentage of its support from its founder, who was one of P's two ministers and two members and who effectively controlled the disposition of P's assets; the founder's living expenses were paid for by P. P's activities included the operation of a library, the publication of a newsletter, and bimonthly meetings. Held,…

1Opinion of the Court

Williams, Judge-.*

The Commissioner determined that petitioner does not qualify for exemption from Federal income taxation under section 501(a)1 as an organization described in section 501(c)(3) or as a church within the meaning of sections 509(a)(1) and 170(b)(l)(A)(i). Petitioner seeks a declaratory judgment of this Court pursuant to section 7428 that it is an exempt organization described in section 501(c)(3) and a church within the meaning of sections 509(a)(1) and 170(b)(l)(A)(i).2

FINDINGS OF FACT

This case was submitted on the stipulated record pursuant to Rules 122 and 217(b).3 The…

2Cases cited11 opinions

  1. United States v. SeegerSupreme Court of the United States · 1965
  2. Church in Boston v. CommissionerUnited States Tax Court · 1978
  3. Unitary Mission Church v. CommissionerUnited States Tax Court · 1980
  4. Basic Bible Church v. CommissionerUnited States Tax Court · 1980
  5. Chapman v. CommissionerUnited States Tax Court · 1967

6 more not listed; retrieve them via the Exa API.

3Cited by21 opinions

  1. Foundation of Human Understanding v. CommissionerUnited States Tax Court · 1987
  2. Foundation of Human Understanding v. United StatesUnited States Court of Federal Claims · 2009
  3. Foundation of Human Understanding v. United StatesCourt of Appeals for the Federal Circuit · 2010
  4. Church of Spiritual Technology v. United StatesUnited States Court of Claims · 1992
  5. Rameses Sch. v. Comm'rUnited States Tax Court · 2007

16 more not listed; retrieve them via the Exa API.

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