The Church of Eternal Life & Liberty, Inc. v. Commissioner
United States Tax Court
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
- United States v. SeegerSupreme Court of the United States · 1965
- Church in Boston v. CommissionerUnited States Tax Court · 1978
- Unitary Mission Church v. CommissionerUnited States Tax Court · 1980
- Basic Bible Church v. CommissionerUnited States Tax Court · 1980
- Chapman v. CommissionerUnited States Tax Court · 1967
6 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Foundation of Human Understanding v. CommissionerUnited States Tax Court · 1987
- Foundation of Human Understanding v. United StatesUnited States Court of Federal Claims · 2009
- Foundation of Human Understanding v. United StatesCourt of Appeals for the Federal Circuit · 2010
- Church of Spiritual Technology v. United StatesUnited States Court of Claims · 1992
- Rameses Sch. v. Comm'rUnited States Tax Court · 2007
16 more not listed; retrieve them via the Exa API.