Puritan Church of America v. COMMISSIONER OF INTERNAL REVENUE
| Citation | 93 US App. DC 129,209 F.2d 306 |
| Decision Date | 05 November 1953 |
| Docket Number | No. 11587,11588.,11587 |
| Parties | PURITAN CHURCH OF AMERICA v. COMMISSIONER OF INTERNAL REVENUE. PURITAN CHURCH BLDG. FUND v. COMMISSIONER OF INTERNAL REVENUE. |
| Court | United States Courts of Appeals. United States Court of Appeals (District of Columbia) |
Mr. Roy St. Lewis, Washington, D. C., for petitioners.
Mr. Harry Baum, Sp. Asst. to Atty. Gen., Dept. of Justice, of the bar of the Court of Appeals of New York, pro hac vice, by special leave of Court, Washington, D. C., with whom Mr. Ellis N. Slack, Sp. Asst. to Atty. Gen., Dept. of Justice, Washington, D. C., was on the brief, for respondent.
Mr. Rollin H. Transue, Sp. Atty., Bureau of Internal Revenue, Washington, D. C., also entered an appearance for respondent.
Before EDGERTON, PRETTYMAN and FAHY, Circuit Judges.
Petition for Rehearing in Banc Denied December 11, 1953.
These are petitions for review of decisions of the Tax Court of the United States, which sustained deficiencies in income taxes proposed against the petitioners, and also sustained proposed penalties. The Puritan Church of America — The Church of America — claimed to be exempt from income taxes as a corporation organized and operated exclusively for religious purposes.1 The liability against the Puritan Church Building Fund was proposed and sustained as a liability of a transferee of property of a taxpayer, that is, the Puritan Church of America.2 The penalties were against the Church and were for failure to file a return3 and for fraud with intent to evade the tax.4 Solution of the controversy depended upon findings of facts. The Tax Court made findings in great detail and rendered a careful opinion. Upon examination of the record we conclude that the findings are supported by ample substantial evidence. We find no error in any other respect.
Affirmed.
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...(1938) (reviewed by the Board). See Puritan Church The Church of America v. Commissioner, 10 T.C.M. 485, 494 (1951), aff'd, 93 U.S.App.D.C. 129, 209 F.2d 306 (1953), cert. denied, 347 U.S. 975, 74 S.Ct. 787, 98 L.Ed. 1115 (1954); Jones v. Commissioner, 62 T.C. 1 (1974). See also Page v. Com......
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...was followed without further elaboration in Puritan Church of America v. Commissioner, 1951, 10 TCM 485, aff'd per curiam, 1953, 93 U.S.App.D.C. 129, 209 F.2d 306, cert. denied, 1954, 347 U.S. 975, 74 S.Ct. 787, 98 L.Ed. There it stood until 1969 when District Judge Frank Kaufman in a lengt......
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Rambo v. United States, 73-1131
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