Urantia Foundation v. Commissioner
United States Tax Court
P was organized to publish and sell The Urantia Book, and the IRS determined that it was an exempt organization described in sec. 501(c)(3), I.R.C. 1954, and that it was not a private foundation within the meaning of sec. 509(a)(2), I.R.C. 1954. Later, P requested a ruling that for purposes of applying the public support test of sec. 509(a)(2), the customers who ultimately purchased the book should be considered the persons to whom P's sales were made, not the chain…
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P was organized to publish and sell The Urantia Book, and the IRS determined that it was an exempt organization described in sec. 501(c)(3), I.R.C. 1954, and that it was not a private foundation within the meaning of sec. 509(a)(2), I.R.C. 1954. Later, P requested a ruling that for purposes of applying the public support test of sec. 509(a)(2), the customers who ultimately purchased the book should be considered the persons to whom P's sales were made, not the chain bookstores which purchased the book from P and sold it to such customers. However, the IRS ruled that the chain bookstores must…
1Opinion of the Court
OPINION
Simpson, Judge'-
This is an action for declaratory judgment under section 7428 of the Internal Revenue Code of 1954.1 We have before us at this time the Commissioner’s motion to dismiss for lack of jurisdiction. The petitioner has filed an objection to the motion, and a hearing was held on the matter.
The petitioner, Urantia Foundation, is a trust with its principal offices in Chicago, Ill. Its charitable purpose is to publish and sell The Urantia Book, a religious-philosophical work.
In 1959, the Internal Revenue Service determined that the petitioner was a tax-exempt organization…
2Cases cited3 opinions
- Bob Jones University v. SimonSupreme Court of the United States · 1974
- Gladstone Foundation v. CommissionerUnited States Tax Court · 1981
- New Community Senior Citizen Housing Corp. v. CommissionerUnited States Tax Court · 1979
3Cited by11 opinions
- Foundation of Human Understanding v. CommissionerUnited States Tax Court · 1987
- Shut Out Dee-Fence, Inc. v. CommissionerUnited States Tax Court · 1981
- AHW Corp. v. CommissionerUnited States Tax Court · 1982
- High Adventure Ministries, Inc. v. CommissionerUnited States Tax Court · 1983
- Yarish Consulting, Inc. v. Comm'rUnited States Tax Court · 2010
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