Legal Opinion

Shiloh Youth Revival Centers v. Commissioner

United States Tax Court

Decided March 12, 1987No. Docket No. 4223-84Published

Petitioner, a tax-exempt religious organization, engages in forestry, cleaning and maintenance, painting, and a business referred to as "donated labor." Payments for the work performed in petitioner's businesses are made directly to petitioner by the person for whom the work is done. Petitioner, a communal organization, provides for all of its members needs. Held, petitioner's businesses are not substantially related to its exempt purposes.

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Petitioner, a tax-exempt religious organization, engages in forestry, cleaning and maintenance, painting, and a business referred to as "donated labor." Payments for the work performed in petitioner's businesses are made directly to petitioner by the person for whom the work is done. Petitioner, a communal organization, provides for all of its members needs. Held, petitioner's businesses are not substantially related to its exempt purposes. Held, further, because substantially all of the work in carrying on petitioner's businesses is not performed without compensation, petitioner's businesses…

1Opinion of the Court

Shiloh Youth Revival Centers, Petitioner v. Commissioner of Internal Revenue, Respondent

Shiloh Youth Revival Centers v. Commissioner

Docket No. 4223-84

United States Tax Court

88 T.C. 565; 1987 U.S. Tax Ct. LEXIS 23; 88 T.C. No. 29;

March 12, 1987. March 12, 1987, Filed

Decision will be entered under Rule 155.

Petitioner, a tax-exempt religious organization, engages in forestry, cleaning and maintenance, painting, and a business referred to as "donated labor." Payments for the work performed in petitioner's businesses are made directly to petitioner by the person for whom the work is done.…

2Cases cited12 opinions

  1. Helvering v. National Grocery Co.Supreme Court of the United States · 1938
  2. United States v. American Bar EndowmentSupreme Court of the United States · 1986
  3. United States v. American College of PhysiciansSupreme Court of the United States · 1986
  4. Professional Insurance Agents of Michigan v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1984
  5. Professional Ins. Agents v. CommissionerUnited States Tax Court · 1982

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