Legal Opinion

Western Catholic Church v. Commissioner

United States Tax Court

Decided October 31, 1979No. Docket No. 8709-78XPublishedCited by 56 opinions

Petitioner was organized in 1971 for religious purposes. However, it had no place of worship and conducted no public religious services during the years 1972-74. Its only activities, aside from investment activities, were some one-to-one ministry conducted by its founder with individuals who had problems, and distribution of a few grants to needy individuals chosen by the founder.

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Petitioner was organized in 1971 for religious purposes. However, it had no place of worship and conducted no public religious services during the years 1972-74. Its only activities, aside from investment activities, were some one-to-one ministry conducted by its founder with individuals who had problems, and distribution of a few grants to needy individuals chosen by the founder. Petitioner's capital was derived primarily from contributions by its founder who, with his wife and daughter, constituted the board of directors of petitioner. Petitioner's primary activity during 1972-74 was the…

1Opinion of the Court

Drennen, Judge:

This is an action for declaratory judgment pursuant to section 7428(a), I.R.C. 1954.1

Respondent issued a final adverse determination to petitioner on April 25, 1978, in which petitioner’s previously granted tax-exempt status under section 501(c)(3) was retroactively revoked. The revocation was effective as of April 23, 1971, the date petitioner was organized. Based upon an examination of petitioner’s activities during the 1972,1973, and 1974 calendar years, respondent determined that (1) petitioner was not, nor had it ever been, operated exclusively for any of the purposes…

2Cases cited15 opinions

  1. Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
  2. B.S.W. Group, Inc. v. CommissionerUnited States Tax Court · 1978
  3. Church in Boston v. CommissionerUnited States Tax Court · 1978
  4. Hancock Academy of Savannah, Inc. v. CommissionerUnited States Tax Court · 1977
  5. Christian Manner International, Inc. v. CommissionerUnited States Tax Court · 1979

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

3Cited by56 opinions

  1. McGahen v. CommissionerUnited States Tax Court · 1981
  2. Unitary Mission Church v. CommissionerUnited States Tax Court · 1980
  3. American Campaign Academy v. CommissionerUnited States Tax Court · 1989
  4. Church of Transfiguring Spirit, Inc. v. CommissionerUnited States Tax Court · 1981
  5. People of God Community v. CommissionerUnited States Tax Court · 1980

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

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