VIA v. Commissioner

T.C. Memo. 1994-349 (1994)

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VIA v. Commissioner

United States Tax Court
T.C. Memo. 1994-349 (1994)

Facts

VIA (plaintiff) was a California organization focused on the promotion of wellness. Members joined the organization through the payment of a small membership fee, which entitled them to tailored fitness programs and home visits from trained VIA mentors. VIA characterized the home visits as a type of worship in which the sharing and learning of information constituted a form of enlightenment. Additionally, during the visits, mentors led members in a form of group meditation that VIA called harmonization. The home visits were irregularly scheduled and optional. VIA held no other meetings with its members. VIA applied to the Internal Revenue Service (IRS) (defendant) for recognition as a church for federal tax purposes. The IRS denied the application, and VIA petitioned the United States Tax Court to review the IRS’s determination.

Rule of Law

Issue

Holding and Reasoning (Nims, J.)

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