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SPIRITUAL OUTREACH SOC. v. C.I.R.

No. 90-1501.

927 F.2d 335 (1991)

SPIRITUAL OUTREACH SOCIETY, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided February 27, 1991.

Attorney(s) appearing for the Case

Micahel A. Markenson, St. Louis, Mo., for appellant.

Patricia Bowman, Washington, D.C., for appellee.

Before JOHN R. GIBSON, Circuit Judge, HENLEY, Senior Circuit Judge, and CONMY, Chief District Judge.

HENLEY, Senior Circuit Judge.

Spiritual Outreach Society (SOS) appeals the tax court's decision denying its claim for status as a church under I.R.C. §§ 509(a)(1) and 170(b)(1)(A)(i) (1990).1 Spiritual Outreach Society v. Commissioner, Tax Ct.Mem.Dec. (CCH) 1990-41 (1990). On appeal, SOS contends that the tax court erred when it found that SOS neither fulfilled an associational role required of churches nor satisfied the...

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