Truth Tabernacle v. Commissioner

1981 T.C. Memo. 214, 41 T.C.M. 1405, 1981 Tax Ct. Memo LEXIS 530
CourtUnited States Tax Court
DecidedApril 29, 1981
DocketDocket No. 7496-79X.
StatusUnpublished

This text of 1981 T.C. Memo. 214 (Truth Tabernacle v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Truth Tabernacle v. Commissioner, 1981 T.C. Memo. 214, 41 T.C.M. 1405, 1981 Tax Ct. Memo LEXIS 530 (tax 1981).

Opinion

TRUTH TABERNACLE, an unincorporated association, organized and existing under the laws of the State of Maine, by and through REV. JUDAH GATLING, RICHARD TAYLOR, and MARTIN LIEBAU, Trustees and Members of TRUTH TABERNACLE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Truth Tabernacle v. Commissioner
Docket No. 7496-79X.
United States Tax Court
T.C. Memo 1981-214; 1981 Tax Ct. Memo LEXIS 530; 41 T.C.M. (CCH) 1405; T.C.M. (RIA) 81214;
April 29, 1981.
Richard S. Kestenbaum, Larry N. Johnson, and Lewis R. Mandel, for the respondent.

TIETJENS

MEMORANDUM OPINION

TIETJENS, Judge: Respondent determined that petitioner is not exempt from Federal income tax under section 501(c)(3), 1 and that petitioner is not a church. The prerequisites for declaratory judgment having been satisfied, 2 petitioner has, pursuant to section 7428, invoked the jurisdiction of this Court.

*532 The issues for our determination are (1) whether petitioner is organized exclusively for one or more exempt purposes delineated in section 501(c)(3); (2) whether petitioner is operated exclusively for one or more of those exempt purposes; (3) whether any part of petitioner's net earnings inures to the benefit of a private shareholder or individual; and (4) whether petitioner is a church as described in section 170(b)(1)(A)(i).

The case was submitted on a stipulated administrative record under Rules 122 and 217, Tax Court Rules of Practice and Procedure. The stipulated record, which is assumed to be true for the purpose of this proceeding, is incorporated herein by reference.

Petitioner, an unincorporated organization established in 1974 as the Work of Life Tabernacle and subsequently changing its name to Truth Tabernacle, has its principal meeting place in Richmond, Maine. Prior to respondent's issuing an adverse ruling letter to petitioner, no Application for Recognition of Exemption was filed. 3

*533 On March 9, 1979, respondent issued to petitioner a final adverse ruling letter which denied petitioner tax-exempt status for the following reasons:

that Truth Tabernacle fails to meet the organizational test of Section 1.501(c)(3)-1(b) of the Regulations ince its assets are not dedicated to an exempt purpose.

Truth Tabernacle also fails to meet the operational test set forth in section 1.501(c)(3)-1(c) of the Regulations since it has not established that it is a church. No information has been furnished to show that the organization conducts religious services and has a regular congregation of persons who meet regularly. You maintain neither a seminary nor a bible school, and your members are drawn from many churches and remain affiliated with those churches. It appears that you seek converts to the principals [sic] of christianity generally.

Moreover, Truth Tabernacle fails to meet the operational test since the information submitted indicates that it is serving the private interest of the Reverend Judah Gatling, its General Overseer, who virtually operates and controls the church at his will. In addition it also serves the private interest of other trustees.

Furthermore, *534 Truth Tabernacle has not maintained proper financial records so that it can be determined that its expenditures are used for charitable purposes. No information has been provided with respect to income and contributions received by you. The general statement of expenses for 1976 that was provided by Truth Tabernacle only discloses that the majority of money spent by the organization was for maintenance and upkeep of the property.There is, as a result, insufficient information to determine whether Truth Tabernacle is operated exclusively for any exempt purpose.

There are no written articles of association or corporate charter. Under the bylaws, the General Overseer, a position held by the Reverend Judah Gatling (Gatling), determines qualifications for active and associate membership, the suspension of any member, the number of meetings (apart from one annual meeting, undescribed in nature, on March 10th of each year), the nomination and removal of officers, the composition of the Mothers of Israel Committee who are in charge of cleaning and maintaining the association's building, who instruct young women in the Word of God, and who are in charge of the children's and ladies' activites. *535 Essentially, the General Overseer's duties, according to the organization's bylaws, are "to supervise, control and direct the affairs of the association." Gatling is also a trustee of petitioner and has exclusive control of petitioner's property.The bylaws lack a statement regarding petitioner's purpose. 4

*536 Unaffiliated with any organized religious denomination, petitioner does not subscribe to any formal creed or dogma. Petitioner has approximately 56 members, but members are not required to meet any formal conditions or to renounce their former, or other, religious beliefs.

Petitioner's beliefs include the infallibility of the Christian Bible. Gatling states, "We do not have a creed but Christ. No law but love. No book but the Bible." Evangelical services are conducted on a weekly basis.

Petitioner is situated on Highway 201, in Richmond, Maine on 5 acres of land. Gatling resides in an apartment of one of the buildings on a rent-free basis. Petitioner, in addition, pays all the utilities for this apartment.

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Bluebook (online)
1981 T.C. Memo. 214, 41 T.C.M. 1405, 1981 Tax Ct. Memo LEXIS 530, Counsel Stack Legal Research, https://law.counselstack.com/opinion/truth-tabernacle-v-commissioner-tax-1981.