- 5 - (1988); Taylor v. Commissioner, T.C. Memo. 2000-17. To qualify for exemption under section 501(c)(3), the entity must (1) be organized and operated exclusively for religious or charitable purposes, (2) have no part of its earnings inuring to the benefit of a private individual, and (3) have no substantial part of its activities consist of the dissemination of propaganda or be otherwise attempting to influence legislation. Sec. 1.501(c)(3)- 1, Income Tax Regs. Although they are separate requirements, the “private inurement” test and the “operated exclusively for exempt purposes” test prescribed by section 501(c)(3) often substantially overlap. Church of Ethereal Joy v. Commissioner, 83 T.C. 20, 21 (1984). It is these two tests, in conjunction, that the Court addresses in deciding this case. Petitioner claims that the Center operated exclusively for an exempt purpose, as a church, contending that the Center held regular services, received offerings, and had a clearly identifiable membership. Despite this testimony, however, petitioner offered little evidence to substantiate his claim. There is no evidence that petitioner, as its pastor, performed marriages, burials, baptisms, or other sacerdotal functions, and, while petitioner did obtain an associate’s degree from West Angeles Church in California, he is not a licensed or ordained minister. Furthermore, although petitioner testified the Center kept books and records documenting the offerings it received andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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