Legal Opinion

Moriarty Commissioner

United States Tax Court

Decided October 9, 1984No. Docket No. 19915-83UnpublishedCited by 2 opinions

Held: Petitioners failed to establish that they made any charitable contributions to the Universal Life Church, Inc., of Modesto, California, or that the contributions they made to their own Universal Life Church "congregations" qualified as charitable contributions. Held further: Petitioners are liable for additions to tax under sec. 6653(a), and damages are awarded to the United States under sec. 6673.

1Opinion of the Court

WILLIAM and ANNE MORIARTY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Moriarty Commissioner

Docket No. 19915-83.

United States Tax Court

T.C. Memo 1984-539; 1984 Tax Ct. Memo LEXIS 129; 48 T.C.M. (CCH) 1345; T.C.M. (RIA) 84539;

October 9, 1984.

Held: Petitioners failed to establish that they made any charitable contributions to the Universal Life Church, Inc., of Modesto, California, or that the contributions they made to their own Universal Life Church "congregations" qualified as charitable contributions. Held further: Petitioners are liable for additions to tax under sec.…

2Cases cited11 opinions

  1. Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
  2. Davis v. CommissionerUnited States Tax Court · 1983
  3. Basic Bible Church v. CommissionerUnited States Tax Court · 1980
  4. Sydnes v. CommissionerUnited States Tax Court · 1980
  5. Universal Life Church, Inc. v. United StatesDistrict Court, E.D. California · 1974

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

3Cited by2 opinions

  1. Universal Life Church, Inc. v. United StatesUnited States Court of Claims · 1987
  2. Universal Life Church, Inc. v. United StatesUnited States Court of Claims · 1986

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