Church of Transfiguring Spirit, Inc. v. Commissioner
United States Tax Court
Where virtually all of the income of petitioner, a religious organization, was contributed by two of its ministers, virtually all of such income was paid as housing allowances for the benefit of those ministers, and virtually all of the control of petitioner was in those ministers. Held, respondent's determination that petitioner is not an organization described in sec. 501(c)(3), I.R.C. 1954, sustained.
1Opinion of the Court
OPINION
Ekman, Judge:
This is an action for declaratory judgment pursuant to section 7428.1 The case was submitted on a stipulated record under Rule 122, Tax Court Rules of Practice and Procedure,2 and the stipulated record is incorporated herein by this reference.
Petitioner, the Church of the Transfiguring Spirit, Inc., was incorporated on January 8,1979, under the Non-Profit Corporation Act of New Mexico. Its principal office at the time of filing its petition was in New Mexico. The petitioner originally filed for exemption under section 501(c)(3) on February 27, 1979. Respondent issued his…
2Cases cited9 opinions
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- The Founding Church of Scientology v. The United StatesUnited States Court of Claims · 1969
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- Church by Mail, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
- Presbyterian and Reformed Publishing Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1984
- Ecclesiastical Order of ISM of AM, Inc. v. CommissionerUnited States Tax Court · 1983
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