Church of Ethereal Joy v. Commissioner
United States Tax Court
In this declaratory judgment action filed pursuant to sec. 7428(a), I.R.C. 1954, petitioner seeks tax-exempt status under sec. 501(c)(3), I.R.C. 1954, and exemption as a church under sec. 509(a)(1), I.R.C. 1954. Petitioner has not engaged in any activities, religious or otherwise. It is controlled by a self-perpetuating board of three directors, and at least one of its directors participates in the promotion of the organization of mail-order "churches."
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In this declaratory judgment action filed pursuant to sec. 7428(a), I.R.C. 1954, petitioner seeks tax-exempt status under sec. 501(c)(3), I.R.C. 1954, and exemption as a church under sec. 509(a)(1), I.R.C. 1954. Petitioner has not engaged in any activities, religious or otherwise. It is controlled by a self-perpetuating board of three directors, and at least one of its directors participates in the promotion of the organization of mail-order "churches." Held, petitioner has not shown that it is organized and operated, or will be operated, exclusively for public rather than the private benefit…
1Opinion of the Court
OPINION
Featherston, Judge-.
In this action, petitioner seeks a declaratory judgment pursuant to section 7428(a)1 that it qualifies for tax-exempt status under section 501(c)(3) and as a church under section 509(a)(1). Upon completion of the administrative consideration of petitioner’s status, the Internal Revenue Service issued a ruling in part as follows:
This is a final adverse determination with respect to your exempt status under section 501(c)(3) of the Internal Revenue Code.
The adverse determination was made because you are not operated exclusively in furtherance of one or more of the…
2Cases cited10 opinions
- William R. And Lorna E. Hall v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- Davis v. CommissionerUnited States Tax Court · 1983
- Basic Bible Church v. CommissionerUnited States Tax Court · 1980
- Bubbling Well Church of Universal Love, Inc. v. CommissionerUnited States Tax Court · 1980
- Western Catholic Church v. CommissionerUnited States Tax Court · 1979
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