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Hernandez v. Commissioner

490 US 680 (1989)

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Hernandez v. Commissioner

United States Supreme Court

490 US 680 (1989)

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Facts

Hernandez (plaintiff) was a member of the Church of Scientology. Hernandez made payments to the church in return for auditing and training sessions the church offered. The church had fixed prices for these sessions and would offer refunds if portions of a paid-for session went unused. A church member could gain “spiritual awareness by progressing through sequential levels of auditing.” Further, a church member could only become an auditor by going through a series of training sessions. Hernandez deducted his payments for these auditing and training sessions from his federal income taxes as charitable contributions. The Internal Revenue Service (IRS) (defendant) disallowed these deductions. Hernandez appealed the decision to federal court. The United States Tax Court ruled that the payments were not deductible. United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Marshall, J.)

Dissent (O’Connor, J.)

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