Synanon Church v. Commissioner
United States Tax Court
Petitioner's exemption from income taxes was revoked in May 1982 retroactively to the beginning of its fiscal year 1977. Deficiencies were determined for the fiscal years 1977 through 1983. It is Held, that petitioner is entitled to have its income from Adgap, its principal source of income, determined in the light of all the evidence, not just the Adgap ledgers; Held further,sec. 277, I.R.C. 1954, is not applicable because petitioner was not operated primarily to furnish…
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Petitioner's exemption from income taxes was revoked in May 1982 retroactively to the beginning of its fiscal year 1977. Deficiencies were determined for the fiscal years 1977 through 1983. It is Held, that petitioner is entitled to have its income from Adgap, its principal source of income, determined in the light of all the evidence, not just the Adgap ledgers; Held further,sec. 277, I.R.C. 1954, is not applicable because petitioner was not operated primarily to furnish goods and services to its members, whether all the residents of the Synanon communities or only the members of the Board…
1Opinion of the Court
THE SYNANON CHURCH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Synanon Church v. Commissioner
Docket No. 20015-84.
United States Tax Court
T.C. Memo 1989-270; 1989 Tax Ct. Memo LEXIS 270; 57 T.C.M. (CCH) 602; T.C.M. (RIA) 89270;
June 7, 1989; As corrected June 7, 1989
Petitioner's exemption from income taxes was revoked in May 1982 retroactively to the beginning of its fiscal year 1977. Deficiencies were determined for the fiscal years 1977 through 1983. It is
Held, that petitioner is entitled to have its income from Adgap, its principal source of income, determined in the light of…
2Cases cited91 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Helvering v. CliffordSupreme Court of the United States · 1940
- United States v. BoyleSupreme Court of the United States · 1985
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- Estate of Clopton v. CommissionerUnited States Tax Court · 1989
- Baggett v. CommissionerUnited States Tax Court · 1991
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