Jack Lane Taylor - Page 4

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          affd. without published opinion 767 F.2d 931 (9th Cir. 1985).3              
          These rules apply with equal force to deductions claimed for                
          charitable contributions.  See Davis v. Commissioner, supra.                
               Petitioner concedes that during the year in issue IBT was              
          not an organization defined in section 501(c)(3) and, by                    
          implication, we understand him not to assert that IBT is an                 
          organization defined in section 170(c)(2).  Rather, petitioner              
          contends that his donations to IBT are deductible because IBT is            
          not a “corporation”, but a “church”.  As a church, petitioner               
          contends, IBT is exempt from having to meet the requirements of             
          section 170(c)(2).  He relies on section 508(c)(1) for support              
          for his position.                                                           
               Section 508(c)(1)(A) provides that churches, their                     
          integrated auxiliaries, and conventions or associations of                  
          churches are excepted from the general rule of section 508(a).              
          Section 508(a) provides that organizations described in section             
          501(c)(3) and organized after October 9, 1969, are required to              
          apply formally for recognition of their tax-exempt status.  Thus,           
          section 508(c)(1) simply relieves churches from applying for a              
          favorable determination letter regarding their exempt status as             
          required by section 508(a).  Nothing in section 508(c)(1)                   

          3  Cf. sec. 7491, effective for court proceedings arising in                
          connection with examinations commencing after July 22, 1998.                

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