Church of Spiritual Technology v. United States

OPINION

BRUGGINK, Judge.

This is an appeal from a decision rendered by the Commissioner of the Internal Revenue Service (“IRS”). The Church of Spiritual Technology (“CST”),2 plaintiff, applied for tax-exempt status under I.R.C. § 501(c)(3) (1982) as a religious organization.3 On July 8, 1988, the IRS issued its final adverse ruling denying CST’s bid for tax exemption. CST appealed that administrative decision to the court pursuant to I.R.C. § 7428(a), resulting in the instant case.

The IRS denied CST’s application because the organization failed to establish that it was operated exclusively for…