Bubbling Well Church of Universal Love, Inc. v. Commissioner
United States Tax Court
Held, in an action for declaratory judgment under sec. 7428(a), I.R.C. 1954, the administrative record does not establish that no part of petitioner's net earnings inure to the benefit of private individuals in violation of sec. 501(c)(3), I.R.C. 1954.
1Opinion of the Court
Featherston, Judge:
This is an action for declaratory judgment pursuant to section 7428(a).1 Petitioner filed an application for recognition of exemption from Federal income tax on June 9, 1977, seeking exemption under section 501(c)(3) and claiming to be a church within the meaning of sections 509(a)(1) and 170(b)(l)(A)(i). Upon completion of the administrative consideration of petitioner’s status, the Internal Revenue Service on April 11,1979, issued an adverse ruling in part as follows:
You are neither organized nor operated for one or more exempt purposes within the meaning of section…
2Cases cited10 opinions
- The Founding Church of Scientology v. The United StatesUnited States Court of Claims · 1969
- Parker v. CommissionerCourt of Appeals for the Eighth Circuit · 1966
- Unitary Mission Church v. CommissionerUnited States Tax Court · 1980
- Christian Echoes National Ministry, Inc. v. United StatesCourt of Appeals for the Tenth Circuit · 1973
- Universal Life Church, Inc. v. United StatesDistrict Court, E.D. California · 1974
5 more not listed; retrieve them via the Exa API.
3Cited by62 opinions
- Davis v. CommissionerUnited States Tax Court · 1983
- McGahen v. CommissionerUnited States Tax Court · 1981
- Church of Scientology v. CommissionerUnited States Tax Court · 1984
- Basic Bible Church v. CommissionerUnited States Tax Court · 1980
- Bubbling Well Church of Universal Love, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1981
57 more not listed; retrieve them via the Exa API.