People of God Community v. Commissioner
United States Tax Court
Petitioner is a newly formed Christian religious organization located in southern California. Petitioner's ministers are each paid predetermined percentages of the gross tithes and offerings received. Held: Part of petitioner's net earnings inure to the benefit of private shareholders or individuals. Accordingly, petitioner is not exempt as an organization described in sec. 501(c)(3), I.R.C. 1954.
1Opinion of the Court
OPINION
Fay, Judge:
Respondent determined petitioner does not qualify for exemption from Federal income tax as an organization described in section 501(c)(3).1 Having exhausted its administrative remedies as required by section 7428(b)(2), petitioner has timely invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428(a). The issues are whether petitioner is operated exclusively for religious or other exempt purposes and whether part of petitioner’s net earnings inures to the benefit of private individuals. If we find petitioner is an organization described in…
2Cases cited10 opinions
- Hancock Academy of Savannah, Inc. v. CommissionerUnited States Tax Court · 1977
- The Founding Church of Scientology v. The United StatesUnited States Court of Claims · 1969
- Unitary Mission 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
5 more not listed; retrieve them via the Exa API.
3Cited by37 opinions
- McGahen v. CommissionerUnited States Tax Court · 1981
- Church of Scientology v. CommissionerUnited States Tax Court · 1984
- Tobler v. DerwinskiUnited States Court of Appeals for Veterans Claims · 1991
- American Campaign Academy v. CommissionerUnited States Tax Court · 1989
- Church of Transfiguring Spirit, Inc. v. CommissionerUnited States Tax Court · 1981
32 more not listed; retrieve them via the Exa API.