Foundation for Devine Meditation, Inc. v. Commissioner
United States Tax Court
FDM not entitled to exemption under sec. 501(c)(3) because it was not organized and operated exclusively for religious purposes. Its publication and distribution of various materials constituted a substantial nonexempt activity. Parker realized taxable income from certain items, including litigation expenses paid by FDM on his behalf.
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FDM not entitled to exemption under sec. 501(c)(3) because it was not organized and operated exclusively for religious purposes. Its publication and distribution of various materials constituted a substantial nonexempt activity. Parker realized taxable income from certain items, including litigation expenses paid by FDM on his behalf. Both FDM and Parker are liable for additions to tax under sec. 6651(a), I.R.C. 1954, for failure to file returns, and FDM is liable for additions to tax for underpayment of taxes under sec. 6653(a), I.R.C. 1954.
1Opinion of the Court
The Foundation for Divine Meditation, Incorporated v. Commissioner. Merle E. Parker v. Commissioner.
Foundation for Devine Meditation, Inc. v. Commissioner
Docket Nos. 2601-62, 2600-62.
United States Tax Court
T.C. Memo 1965-77; 1965 Tax Ct. Memo LEXIS 248; 24 T.C.M. (CCH) 411; T.C.M. (RIA) 65077;
April 5, 1965
FDM not entitled to exemption under sec. 501(c)(3) because it was not organized and operated exclusively for religious purposes. Its publication and distribution of various materials constituted a substantial nonexempt activity.
Parker realized taxable income from certain items, including…
2Cases cited15 opinions
- United States v. SeegerSupreme Court of the United States · 1965
- Niemotko v. MarylandSupreme Court of the United States · 1951
- United States v. BallardSupreme Court of the United States · 1944
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
- Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
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