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People of God Community v. Commissioner

75 T.C. 127 (1980)

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People of God Community v. Commissioner

United States Tax Court
75 T.C. 127 (1980)

Facts

Charles Donhowe was the founder and principal pastor of the People of God Community (People of God) (plaintiff), a church. Donhowe also served on People of God’s board of directors. People of God compensated Donhowe by paying him a percentage of what remained of the gross tithes after People of God satisfied its annual loan obligations. People of God did not make clear how it chose Donhowe’s percentage each year, although People of God did adjust the percentage upward when Donhowe’s personal expenses increased and downward when the pool of gross tithes increased. The Internal Revenue Service (IRS) (defendant) took the position that People of God used its net earnings to benefit Donhowe, disqualifying People of God from tax-exempt status. People of God petitioned the United States Tax Court for a declaratory judgment finding that it was tax-exempt.

Rule of Law

Issue

Holding and Reasoning (Fay, J.)

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Casebooks

Taxation of Nonprofit and Exempt Organizations

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