US Tax Court Decision: CSC v. Commissioner of Internal Revenue (Excerpt) (September 24, 1984)

CHURCH OF SCIENTOLOGY OF CALIFORNIA, Petitioner

v.

COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 3352-78.

United States Tax Court

Filed September 24, 1984.1

[…]

On July 18, 1967, respondent revoked petitioner’s tax exemption and instructed petitioner it was thereafter required to file a Federal income tax return, in petitioner’s case, Form 1120. Petitioner ignored this instruction and continued to file its returns on Forms 990 ‘Return of Organization Exempt From Income Tax.’ Petitioner claims that it was justified in continuing to file its returns on Forms 990 since the revocation of exemption was null and void. We hold in Part II of this opinion that the revocation was valid and effective.

Petitioner’s unilateral doubts about its effectiveness are not ‘reasonable cause’ for its failure to file a proper return.

Decision will be entered under Rule 155.

Notes