GillisTriplett - Page 6

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          (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 and            






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