Court Ruled Taxpayer Could Not Deduct a Charitable Contribution Made to His Local Branch of the “Universal Life Church”

The Tax Court ruled that a taxpayer could not deduct an alleged charitable contribution made

The Tax Court ruled that a taxpayer could not deduct an alleged charitable contribution made to his local branch of the "Universal Life Church."

The taxpayer, an airline pilot, established a local "chapter" of the Universal Life Church in his home, and established a church "checking account" at a local bank. The taxpayer and his family apparently were the only members of the church, and a number of checks were drawn on the church's account to pay for personal expenses of members of the taxpayer's family.

In denying a deduction for contributions made to the "church," the court observed that the taxpayer had failed to establish that his church qualified as a tax-exempt organization under federal law, and that he never parted with control over the alleged contributions.

Labeling the taxpayer's allegations "ludicrous" and "frivolous," the court awarded the government $5,000 in damages besides the additions to tax. Dunn v. Commissioner, T.C. Memo. 1988-45 (1988)

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