National Asso. of American Churches v. Commissioner
United States Tax Court
Petitioner, having been denied tax-exempt status as a religious organization under sec. 501(c)(3), I. R. C. 1954, as amended, petitioned this Court for a declaratory judgment pursuant to sec. 7428. Petitioner is a central organization whose membership consists of separately incorporated family missions.
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Petitioner, having been denied tax-exempt status as a religious organization under sec. 501(c)(3), I. R. C. 1954, as amended, petitioned this Court for a declaratory judgment pursuant to sec. 7428. Petitioner is a central organization whose membership consists of separately incorporated family missions. In addition to its stated religious activities, petitioner provides assistance to the family missions in incorporating under State law and in handling any tax disputes which may arise concerning the missions' claimed tax-exempt status. Petitioner promotes tax seminars for its members. The…
1Opinion of the Court
Swift, Judge:
This is an action for declaratory judgment pursuant to section 7428.2 Petitioner filed an application with the Internal Revenue Service for recognition of exemption from Federal income taxes on March 11, 1980, seeking exemption under section 501(c)(3) and claiming to be a church within the meaning of section 170(b)(l)(A)(i). The application was filed as a group ruling request under Rev. Proc. 80-27, 1980-1 C.B. 677, seeking a determination of exempt status for petitioner and 72 affiliated missions.
After extensive efforts by respondent at the administrative level to obtain…
2Cases cited19 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Johnson v. RobisonSupreme Court of the United States · 1974
- United States v. LeeSupreme Court of the United States · 1982
- Bob Jones University v. SimonSupreme Court of the United States · 1974
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
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3Cited by27 opinions
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