Twin Oaks Community, Inc. v. Commissioner
United States Tax Court
P, a religious or apostolic organization operating as a nonstock corporation under the laws of the Commonwealth of Virginia, conducts various businesses for the common benefit of its members. All the earnings generated by P are deposited in a community treasury maintained by P from which the needs of its members are met.
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P, a religious or apostolic organization operating as a nonstock corporation under the laws of the Commonwealth of Virginia, conducts various businesses for the common benefit of its members. All the earnings generated by P are deposited in a community treasury maintained by P from which the needs of its members are met. Each year P's members include in their gross income their entire pro rata shares of P's taxable income and properly report it as a dividend received from P. P does not require its members to take a vow of poverty and contribute all of their property, both real and personal,…
1Opinion of the Court
PARKER, Judge:
Respondent determined deficiencies in petitioner’s Federal income tax as follows:
Year Deficiency
1977.$19,542.74
1978. 7,274.55
1979. 8,946.01
1980. 7,489.00
The issue for decision is whether petitioner, which is otherwise qualified as a tax-exempt organization under section 501(d),1 satisfies the requirement for a “common treasury” or “community treasury.” Resolution of this issue depends on whether the terms “common treasury” or “community treasury,” as used in section 501(d), refer only to a religious or apostolic organization that requires its members to take a vow of poverty and…
2Cases cited19 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- United States v. Trans-Missouri Freight Assn.Supreme Court of the United States · 1897
- Duplex Printing Press Co. v. DeeringSupreme Court of the United States · 1921
- Pennsylvania Railroad v. International Coal Mining Co.Supreme Court of the United States · 1913
- United States v. Union Pacific RailroadSupreme Court of the United States · 1875
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3Cited by8 opinions
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- Knapp v. CommissionerUnited States Tax Court · 1988
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