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UNITARY MISSION CHURCH v. COMMISSIONER

Docket No. 8268-79X.

74 T.C. 507 (1980)

UNITARY MISSION CHURCH OF LONG ISLAND, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 3, 1980.

Attorney(s) appearing for the Case

Sheridan Albert, for the petitioner.

Elizabeth D. DePriest, for the respondent.

OPINION

TIETJENS, Judge:

Respondent determined that petitioner is not exempt from Federal income tax under section 501(c)(3),1 and that petitioner does not qualify as a church under section 170(b)(1)(A)(i). Petitioner has invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428.2

The issues for our determination are: (1) Whether any part of petitioner...

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