Foundation of Human Understanding v. Commissioner
United States Tax Court
Petitioner was formed to spread the religious teachings of its founder through a broadcasting and publishing ministry. In addition to its broadcasting and publishing efforts, petitioner regularly conducts religious services at two locations where followers of petitioner's founder congregate.
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Petitioner was formed to spread the religious teachings of its founder through a broadcasting and publishing ministry. In addition to its broadcasting and publishing efforts, petitioner regularly conducts religious services at two locations where followers of petitioner's founder congregate. Petitioner requested a ruling that it was a nonprivate foundation as a church within the meaning of secs. 509(a)(1) and 170(b)(1)(A)(i), I.R.C. 1954. Respondent determined that petitioner was a nonprivate foundation as a publicly supported organization under secs. 509(a)(1) and 170(b)(1)(A)(vi), I.R.C.…
1Opinion of the Court
OPINION
GOFFE, Judge:
In 1965, the Internal Revenue Service issued a ruling letter which recognized that petitioner is exempt from Federal income tax as an organization described in section 501(c)(3).1 The Commissioner subsequently recognized petitioner as a nonprivate foundation because petitioner satisfied the requirements of a publicly supported organization described in sections 509(a)(1) and 170(b)(l)(A)(vi). Petitioner later requested a ruling to modify its exemption so that it would be recognized as a nonprivate foundation under section 509(a)(1) because it is a “church” within the…
2Cases cited18 opinions
- Davis v. CommissionerUnited States Tax Court · 1983
- Hancock Academy of Savannah, Inc. v. CommissionerUnited States Tax Court · 1977
- Houston Lawyer Referral Service, Inc. v. CommissionerUnited States Tax Court · 1978
- Parker v. CommissionerCourt of Appeals for the Eighth Circuit · 1966
- Unitary Mission Church v. CommissionerUnited States Tax Court · 1980
13 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Loftus v. CommissionerUnited States Tax Court · 1988
- Foundation of Human Understanding v. United StatesUnited States Court of Federal Claims · 2009
- Spiritual Outreach Society v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1991
- Foundation of Human Understanding v. United StatesCourt of Appeals for the Federal Circuit · 2010
- Church of Spiritual Technology v. United StatesUnited States Court of Claims · 1992
13 more not listed; retrieve them via the Exa API.