Legal Opinion

Dew v. Commissioner

United States Tax Court

Decided September 14, 1988No. Docket No. 16143-84PublishedCited by 8 opinions

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

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  3. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  4. Bixby v. CommissionerUnited States Tax Court · 1972
  5. Enoch v. CommissionerUnited States Tax Court · 1972

12 more not listed; retrieve them via the Exa API.

3Cited by8 opinions

  1. Church of World Peace v. CommissionerUnited States Tax Court · 1994
  2. Bradley v. Comm'rUnited States Tax Court · 2011
  3. Dew v. CommissionerUnited States Tax Court · 1988
  4. Fox v. CommissionerUnited States Tax Court · 1989
  5. Hall v. CommissionerUnited States Tax Court · 1990

3 more not listed; retrieve them via the Exa API.

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