Legal Opinion

Dew v. Commissioner

United States Tax Court

Decided September 14, 1988No. Docket No. 16143-84Published

P's local charter or chapter of Universal Life Church (ULC No. 21686) engaged in a daisy chain circular flow of moneys within a group of friends and coworkers of a computer company.

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P's local charter or chapter of Universal Life Church (ULC No. 21686) engaged in a daisy chain circular flow of moneys within a group of friends and coworkers of a computer company. ULC No. 21686 had no meeting place, no telephone, and no employees but had use of a computer and a bank account into which 45 to 48 members, at least 25 of whom were mail-order "ministers," placed funds, which they deducted as charitable contributions, and from which they received back either checks directly payable to themselves or checks to third persons in payment of a list of personal expenses each "minister"…

1Opinion of the Court

James Edward Dew, Petitioner v. Commissioner of Internal Revenue, Respondent

Dew v. Commissioner

Docket No. 16143-84

United States Tax Court

91 T.C. 615; 1988 U.S. Tax Ct. LEXIS 121; 91 T.C. No. 38;

September 14, 1988; As amended September 27, 1988 September 14, 1988, Filed

Decision will be entered for the respondent.

P's local charter or chapter of Universal Life Church (ULC No. 21686) engaged in a daisy chain circular flow of moneys within a group of friends and coworkers of a computer company. ULC No. 21686 had no meeting place, no telephone, and no employees but had use of a computer and a bank…

2Cases cited18 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  3. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  4. Bixby v. CommissionerUnited States Tax Court · 1972
  5. Enoch v. CommissionerUnited States Tax Court · 1972

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