Shiloh Youth Revival Centers v. Commissioner
United States Tax Court
Petitioner, a tax-exempt religious organization, engages in forestry, cleaning and maintenance, painting, and a business referred to as "donated labor." Payments for the work performed in petitioner's businesses are made directly to petitioner by the person for whom the work is done. Petitioner, a communal organization, provides for all of its members needs. Held, petitioner's businesses are not substantially related to its exempt purposes.
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Petitioner, a tax-exempt religious organization, engages in forestry, cleaning and maintenance, painting, and a business referred to as "donated labor." Payments for the work performed in petitioner's businesses are made directly to petitioner by the person for whom the work is done. Petitioner, a communal organization, provides for all of its members needs. Held, petitioner's businesses are not substantially related to its exempt purposes. Held, further, because substantially all of the work in carrying on petitioner's businesses is not performed without compensation, petitioner's businesses…
1Opinion of the Court
COHEN, Judge:
Respondent determined deficiencies in petitioner’s income tax as follows:
Year Deficiency
1977. $413,171
1978. 317,460
After concessions, the issues for decision are: (1) Whether certain activities conducted by petitioner (an organization exempt from income tax pursuant to section 501)1 constitute the conduct of unrelated trades or businesses within the meaning of section 513 and, if so, (2) whether substantially all of the work in carrying on the trades or businesses was performed without compensation.
FINDINGS OF FACT
Some of the facts have been stipulated, and the facts set forth in…
2Cases cited11 opinions
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- United States v. American Bar EndowmentSupreme Court of the United States · 1986
- United States v. American College of PhysiciansSupreme Court of the United States · 1986
- Professional Insurance Agents of Michigan v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1984
- Professional Ins. Agents v. CommissionerUnited States Tax Court · 1982
6 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Veterans of Foreign Wars, Dep't of Michigan v. CommissionerUnited States Tax Court · 1987
- Synanon Church v. CommissionerUnited States Tax Court · 1989
- Alamo Found. v. CommissionerUnited States Tax Court · 1992
- California Thoroughbred Breeders Ass'n v. CommissionerUnited States Tax Court · 1989
- National League of Postmasters v. CommissionerUnited States Tax Court · 1995
2 more not listed; retrieve them via the Exa API.