Dew v. Commissioner
United States Tax Court
P's local charter or chapter of Universal Life Church (ULC No. 21686) engaged in a daisy chain circular flow of moneys within a group of friends and coworkers of a computer company.
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P's local charter or chapter of Universal Life Church (ULC No. 21686) engaged in a daisy chain circular flow of moneys within a group of friends and coworkers of a computer company. ULC No. 21686 had no meeting place, no telephone, and no employees but had use of a computer and a bank account into which 45 to 48 members, at least 25 of whom were mail-order "ministers," placed funds, which they deducted as charitable contributions, and from which they received back either checks directly payable to themselves or checks to third persons in payment of a list of personal expenses each "minister"…
1Opinion of the Court
PARKER, Judge:
Respondent determined deficiencies in and additions to petitioner’s Federal income tax as follows:
_Additions to tax_ Sec. 6653(a) or
Year Deficiency 6653(a)(1)1 Sec. 6653(a)(2)
1980 $3,467.98 $173.40
1981 5,721.00 286.05 50 percent of interest due on $5,721
After concessions by petitioner, the issues remaining for decision are:(1) Whether petitioner is entitled to deductions for charitable contributions to Charter No. 21686 of the Universal Life Church;(2) Whether petitioner is liable for additions to tax for negligence or intentional disregard of rules and regulations under section…
2Cases cited17 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Bixby v. CommissionerUnited States Tax Court · 1972
- Enoch v. CommissionerUnited States Tax Court · 1972
12 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Church of World Peace v. CommissionerUnited States Tax Court · 1994
- Bradley v. Comm'rUnited States Tax Court · 2011
- Dew v. CommissionerUnited States Tax Court · 1988
- Fox v. CommissionerUnited States Tax Court · 1989
- Hall v. CommissionerUnited States Tax Court · 1990
3 more not listed; retrieve them via the Exa API.