NELSON, Circuit Judge:
Appellants William and Lorna Hall deducted $3951 as charitable contributions on their 1976 tax return. Most of this money had been donated to the Church of the United Brotherhood ("CUB"), a chartered congregation of the Universal Life Church, Inc. The congregation was organized by William Hall and two of his friends. It practiced no formal rituals, was not housed in a church building, and, except for the charter, no organizational documents...
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