Universal Life Church, Inc. (Full Circle) v. Commissioner
United States Tax Court
Petitioner Full Circle instituted this action for declaratory judgment pursuant to sec. 7428, I.R.C. 1954. Full Circle received a charter from the Universal Life Church, Modesto, Inc. (ULC). Full Circle claimed "church" status relying on the exempt status of the ULC. Petitioner did not file an application for exempt status with the Internal Revenue Service.
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Petitioner Full Circle instituted this action for declaratory judgment pursuant to sec. 7428, I.R.C. 1954. Full Circle received a charter from the Universal Life Church, Modesto, Inc. (ULC). Full Circle claimed "church" status relying on the exempt status of the ULC. Petitioner did not file an application for exempt status with the Internal Revenue Service. After an examination of Full Circle, respondent issued an adverse determination letter that Full Circle was not an exempt organization within the meaning of sec. 501(c)(3). Held, that respondent had authority to examine Full Circle and…
1Opinion of the Court
OPINION
Panuthos, Special Trial Judge'.
This is an action for declaratory judgment pursuant to section 74281 and Rule 211.2 This matter has been decided pursuant to the provisions of section 7456(d) and Rule 218(a).
Petitioner Universal Life Church, Inc. (Full Circle) (hereinafter Full Circle), through Sherwood W. Mathis,3 filed a petition for declaratory judgment herein on August 24, 1981, after respondent determined that Full Circle was not an organization within the meaning of section 501(c)(3). The issues for decision are: (1) Whether the Tax Court has jurisdiction to consider this matter…
2Cases cited14 opinions
- United States of America and Revenue Agents Clarence H. Isabel and John S. Reid of the Internal Revenue Service v. The El Paso CompanyCourt of Appeals for the Fifth Circuit · 1982
- Davis v. CommissionerUnited States Tax Court · 1983
- Church in Boston v. CommissionerUnited States Tax Court · 1978
- Hancock Academy of Savannah, Inc. v. CommissionerUnited States Tax Court · 1977
- Houston Lawyer Referral Service, Inc. v. CommissionerUnited States Tax Court · 1978
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3Cited by5 opinions
- Burwell v. CommissionerUnited States Tax Court · 1987
- Hughes v. CommissionerUnited States Tax Court · 1994
- Burwell v. CommissionerUnited States Tax Court · 1987
- Mathis v. CommissionerUnited States Tax Court · 1986
- Universal Life Church, Inc. (Full Circle) v. CommissionerUnited States Tax Court · 1984