From Casetext: Smarter Legal Research

Puritan Ch. of Am. v. C.I.R

United States Court of Appeals, District of Columbia Circuit
Nov 5, 1953
209 F.2d 306 (D.C. Cir. 1953)

Opinion

Nos. 11587, 11588.

Argued October 16, 1953.

Decided November 5, 1953. Petition for Rehearing in Banc Denied December 11, 1953.

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.


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. 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. The penalties were against the Church and were for failure to file a return and for fraud with intent to evade the tax. 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.

Int.Rev. Code § 101, 26 U.S.C.A. § 101.

Id. § 311(a)(1).

Id. § 291.

Id. § 293.

Affirmed.


Summaries of

Puritan Ch. of Am. v. C.I.R

United States Court of Appeals, District of Columbia Circuit
Nov 5, 1953
209 F.2d 306 (D.C. Cir. 1953)
Case details for

Puritan Ch. of Am. v. C.I.R

Case Details

Full title:PURITAN CHURCH OF AMERICA v. COMMISSIONER OF INTERNAL REVENUE. PURITAN…

Court:United States Court of Appeals, District of Columbia Circuit

Date published: Nov 5, 1953

Citations

209 F.2d 306 (D.C. Cir. 1953)
93 U.S. App. D.C. 129

Citing Cases

Schreck v. United States

In another case, Fancher v. United States, 10 AFTR 2d 5922, 62-2 USTC ¶ 9819 (D.S.Dak. 1962), the Government…

Rambo v. United States

Support of the position of the Internal Revenue Service comes also from a decision of the Tax Court and two…