Legal Opinion

Pulpit Resource v. Commissioner

United States Tax Court

Decided July 31, 1978No. Docket No. 7976-77XPublished

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

  1. Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
  2. Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
  3. B.S.W. Group, Inc. v. CommissionerUnited States Tax Court · 1978
  4. Hoeme v. CommissionerUnited States Tax Court · 1974
  5. Parker v. CommissionerCourt of Appeals for the Eighth Circuit · 1966

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