Clark v. United States (In re Heritage Village Church & Missionary Fellowship, Inc.)

David Clark, Trustee in bankruptcy for Heritage Village Church and Missionary *105Fellowship, Inc. (PTL), appeals from the district court order dissolving a preliminary injunction issued by the bankruptcy court restraining the Internal Revenue Service from revoking PTL’s tax-exempt status. 87 B.R. 401(D.S.C.1988). We affirm on the reasoning of the district court.

I

PTL was incorporated in South Carolina as a nonprofit organization in February 1973. In May 1973, the IRS granted PTL tax-exempt status pursuant to 26 U.S.C.A. § 501(c)(3) (West 1967 & Supp.1987). In 1983 the IRS initiated an extensive…