Church of Scientology v. Commissioner
United States Tax Court
Petitioner, a Church incorporated in the State of California, was granted tax-exempt status in 1957 under sec. 501(c)(3), I.R.C. 1954. In 1967, respondent sent petitioner a letter revoking its exemption following an audit of petitioner's records which was in part sparked by litigation involving the tax-exempt status of an affiliated Church of Scientology.
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Petitioner, a Church incorporated in the State of California, was granted tax-exempt status in 1957 under sec. 501(c)(3), I.R.C. 1954. In 1967, respondent sent petitioner a letter revoking its exemption following an audit of petitioner's records which was in part sparked by litigation involving the tax-exempt status of an affiliated Church of Scientology. Subsequent to issuing the letter of revocation, respondent conducted several audits of petitioner's records for various tax years and also reviewed the tax status of several affiliated churches. Petitioner was also investigated by several…
1Opinion of the Court
Sterrett, Judge:
Petitioner, the Church of Scientology of California (California Church or Church), was incorporated as a nonprofit corporation in the State of California in 1954. In 1957, respondent recognized petitioner as an organization described in section 501(c)(3)1 exempt from Federal income taxes under section 501(a). In 1967, respondent revoked petitioner’s tax-exempt status. Following an extensive audit of petitioner’s records for the year 1971-74, respondent, by notice of deficiency dated December 28,1977, determined deficiencies in petitioner’s Federal income taxes and additions to…
2Cases cited194 opinions
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- Coolidge v. New HampshireSupreme Court of the United States · 1971
- Welch v. HelveringSupreme Court of the United States · 1933
- Mt. Healthy City School District Board of Education v. DoyleSupreme Court of the United States · 1977
- Santosky v. KramerSupreme Court of the United States · 1982
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3Cited by76 opinions
- Hernandez v. CommissionerSupreme Court of the United States · 1989
- Church of Scientology of California v. Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 1986
- Founding Church of Scientology of Washington, D.C., Inc. v. William H. Webster, Director of the Federal Bureau of Investigation of the United StatesCourt of Appeals for the D.C. Circuit · 1986
- Church of Scientology of California v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Capitol Fed. Sav. & Loan Ass'n v. CommissionerUnited States Tax Court · 1991
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