CHURCH OF SCIENTOLOGY OF CALIFORNIA v. COMMISSIONER

Docket No. 3352-78.

83 T.C. 381 (1984)

CHURCH OF SCIENTOLOGY OF CALIFORNIA, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 24, 1984.


Attorney(s) appearing for the Case

Robert H. Harris, Christopher Cobb, Michael Wells, and Peter Young, specially recognized, for the petitioner.

Martin D. Cohen, for the respondent.


STERRETT, Judge:

Petitioner, the Church of Scientology of California (California Church or Church), was incorporated as a nonprofit corporation in the State of California in 1954. In 1957, respondent recognized petitioner as an organization described in section 501(c)(3)1 exempt from Federal income taxes under section 501(a). In 1967, respondent revoked petitioner's tax-exempt status. Following an extensive audit of petitioner's...

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