Svedahl v. Commissioner
United States Tax Court
The revised receipts and disbursements program of the Universal Life Church, Inc., of Modesto, California, was a sham. Petitioner's "contributions" to pay for disbursements thereunder are not deductible charitable contributions.
1Opinion of the Court
SWIFT, Judge:
In a timely statutory notice of deficiency, respondent determined a deficiency in petitioner’s Federal income tax liability for 1983 in the amount of $2,824 and an addition to tax pursuant to section 6653(a)(1)1 in the amount of $250.92. Respondent filed an amendment to his answer in which he increased the deficiency to $6,314 and increased the addition to tax to $316. Respondent also asserts an addition to tax under section 6653(a)(2) and requests damages be awarded to the United States under section 6673.
After concessions, the issues to be decided are whether petitioner is…
2Cases cited16 opinions
- Estate of Charles T. Franklin, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
- Estate of Franklin v. CommissionerUnited States Tax Court · 1975
- Harold Dejong and Marjorie J. Dejong v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- William R. And Lorna E. Hall v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- Davis v. CommissionerUnited States Tax Court · 1983
11 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Allen v. CommissionerUnited States Tax Court · 1989
- Burwell v. CommissionerUnited States Tax Court · 1987
- Dew v. CommissionerUnited States Tax Court · 1988
- Conklin v. CommissionerUnited States Tax Court · 1988
- Hess v. United StatesDistrict Court, E.D. Washington · 1991
13 more not listed; retrieve them via the Exa API.