Puritan Church of America v. Commissioner of Internal Revenue. Puritan Church Bldg. Fund v. Commissioner of Internal Revenue

209 F.2d 306, 93 U.S. App. D.C. 129

• Court: Court of Appeals for the D.C. Circuit
• Decided: December 11, 1953
• Docket: 11588_1
• Status: Published

Opinion

PER CURIAM.

These are petitions for review of decisions of the Tax Court of the United States, which sustained deficiencies in income taxes proposed against the petitioners, and also sustained proposed penalties. The Puritan Church of America— The Church of America — claimed to be exempt from income taxes as a corporation organized and operated exclusively for religious purposes. 1 2 The liability against the Puritan Church Building Fund was proposed and sustained as a liability of a transferee of property of a taxpayer, that is, the Puritan Church of America. 3 The penalties were against the Church and were for failure to file a return 3 and for fraud with intent to evade the tax. 4 Solution of the controversy depended upon findings of facts. The Tax Court made findings in great detail and rendered a careful opinion. Upon examination of the record we conclude that the findings are supported by ample substantial evidence. We find no error in any other respect.

Affirmed.

1 . Int.Rev.Oode § 101, 26 U.S.C.A. § 101.

2 . Id. § 311(a) (1).

3 . Id. § 291.

4 . Id. § 293.