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CHURCH BY MAIL, INC. v. C.I.R.

No. 84-7663.

765 F.2d 1387 (1985)

CHURCH BY MAIL, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided July 16, 1985.

Attorney(s) appearing for the Case

J.C. Joyce, Blackstock, Joyce, Pollard, Blackstock & Montgomery, Tulsa, Okl., for petitioner-appellant.

Thomas Gick, Michael Paup, Washington, D.C., for respondent-appellee.

Before ALARCON and POOLE, Circuit Judges, and REED, District Judge.

ALARCON, Circuit Judge:

Church By Mail, Inc. (hereinafter the Church) appeals from the tax court's judgment on a stipulated administrative record denying the Church tax-exempt status pursuant to Internal Revenue Code (I.R.C.) §§ 501(a) and 501(c)(3). The Church contends that the tax court erred in finding that the Church is operated for the non-exempt purpose of providing a market for the services of Twentieth Century Advertising Agency (hereinafter Twentieth...

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