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BUBBLING WELL CHURCH OF UNIVERSAL LOVE v. C.I.R.

No. 80-7358.

670 F.2d 104 (1981)

BUBBLING WELL CHURCH OF UNIVERSAL LOVE, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided November 27, 1981.

Attorney(s) appearing for the Case

Peter R. Stromer, San Jose, Cal., for petitioner-appellant.

Ernest J. Brown, Washington, D. C., argued, for respondent-appellee; Michael L. Paup, Chief App. Sec., John F. Murray, Acting Asst. Atty. Gen., Robert A. Berstein, Richard N. Bush, Washington, D. C., on brief.

Before SKOPIL and BOOCHEVER, Circuit Judges, and BILBY, District Judge.

BOOCHEVER, Circuit Judge.

Bubbling Well Church of Universal Love (the Church) appeals the Tax Court's denial, 74 T.C. 531, of its application for tax exempt status under I.R.C. § 501(c)(3). Because the Church failed to show that no part of its net income inured to the benefit of private individuals, we affirm.

The Harberts' family are the sole employees and sole voting directors of the Church. In 1977, the $61,543 1977...

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