Burwell v. Commissioner
United States Tax Court
Petitioners formed charter congregations of the Universal Life Church, Inc., Modesto, opened bank accounts in the name of Universal Life Church, Inc., of which they were sole signatories, and paid various living and personal expenses from such accounts. Held: 1. Petitioners did not make gifts to a tax-exempt organization when they transferred funds into the bank accounts.
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Petitioners formed charter congregations of the Universal Life Church, Inc., Modesto, opened bank accounts in the name of Universal Life Church, Inc., of which they were sole signatories, and paid various living and personal expenses from such accounts. Held: 1. Petitioners did not make gifts to a tax-exempt organization when they transferred funds into the bank accounts. Held, further, petitioners' charter congregations were not such an integral part of Universal Life Church, Inc., Modesto, as to also be tax-exempt at the time of the fund transfer. 2. Petitioners are liable for additions to…
1Opinion of the Court
David C. and Betty B. Burwell, Petitioners v. Commissioner of Internal Revenue, Respondent; James L. Harrold, Petitioner v. Commissioner of Internal Revenue, Respondent
Burwell v. Commissioner
Docket Nos. 22943-83, 9585-84
United States Tax Court
89 T.C. 580; 1987 U.S. Tax Ct. LEXIS 131; 89 T.C. No. 41;
September 16, 1987. September 16, 1987, Filed
Decisions will be entered for the respondent.
Petitioners formed charter congregations of the Universal Life Church, Inc., Modesto, opened bank accounts in the name of Universal Life Church, Inc., of which they were sole signatories, and paid various…
2Cases cited30 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- George v. Zmuda and Walburga Zmuda v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- Zmuda v. CommissionerUnited States Tax Court · 1982
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