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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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