Pulpit Resource v. Commissioner
United States Tax Court
1. Held, in an action brought under sec. 7428(a), I.R.C. 1954, for a declaratory judgment on petitioner's qualification as an exempt organization under sec. 501(a) and (c)( 3), I.R.C. 1954, submitted on the stipulated administrative record, a motion for summary judgment is pointless, and respondent's motion is denied. 2. Held, further, on the facts established by the administrative record and assumed to be true, petitioner was organized and operated exclusively for religious…
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1. Held, in an action brought under sec. 7428(a), I.R.C. 1954, for a declaratory judgment on petitioner's qualification as an exempt organization under sec. 501(a) and (c)( 3), I.R.C. 1954, submitted on the stipulated administrative record, a motion for summary judgment is pointless, and respondent's motion is denied. 2. Held, further, on the facts established by the administrative record and assumed to be true, petitioner was organized and operated exclusively for religious and charitable purposes and qualifies as an exempt organization under sec. 501(a) and (c)( 3), I.R.C. 1954.
1Opinion of the Court
Pulpit Resource, Petitioner v. Commissioner of Internal Revenue, Respondent
Pulpit Resource v. Commissioner
Docket No. 7976-77X
United States Tax Court
70 T.C. 594; 1978 U.S. Tax Ct. LEXIS 87;
July 31, 1978, Filed
Decision will be entered for the petitioner.
1. Held, in an action brought under sec. 7428(a), I.R.C. 1954, for a declaratory judgment on petitioner's qualification as an exempt organization under sec. 501(a) and (c)( 3), I.R.C. 1954, submitted on the stipulated administrative record, a motion for summary judgment is pointless, and respondent's motion is denied.
2. Held, further, on the…
2Cases cited14 opinions
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
- Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
- B.S.W. Group, Inc. v. CommissionerUnited States Tax Court · 1978
- Hoeme v. CommissionerUnited States Tax Court · 1974
- Parker v. CommissionerCourt of Appeals for the Eighth Circuit · 1966
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