TaxProf Blog

Editor: Paul L. Caron, Dean
Pepperdine University School of Law

Tuesday, March 6, 2007

Tax Court Upholds Denial of § 501(c)(3) Tax-Exempt Status to California Organization Dedicated to Educating Public About "Slavery of Hollywood Celebrities"

Tax_court_11The Tax Court yesterday upheld the IRS's denial of § 501(c)(3) tax-exempt status to a California organization dedicated "to educat[ing] the public as to the alleged slavery and entrapment of Hollywood celebrities by Government officials."  Families Against Government Slavery v. Commissioner, T.C. Memo. 2007-49:

Language in the documents that Mr. Matthews distributes to the public at the referred-to demonstrations alleges that the Federal Bureau of Investigation kidnaps Hollywood celebrities and that law enforcement personnel and private gangs are joined in a conspiracy to kill, trap, and enslave Hollywood celebrities and minorities “to gain more financial support” and to engage in activities that petitioner describes as “blood sport”. Language in petitioner’s documents also alleges that Government-sponsored welfare and housing programs force minority women to participate in the above alleged conspiracy. ...

In the documents submitted to respondent and distributed to the public, petitioner utilizes repeatedly and without permission the names of Hollywood celebrities. To protect the privacy of these celebrities and because their names are irrelevant to our opinion, we do not identify their names. ...

In total, petitioner submitted to respondent more than 1,000 pages of documents consisting largely of nonsensical, emotionally charged, and incomprehensible allegations. ...

Educational purposes [under § 501(c)(3)] do not include activities principally involving the presentation of unsupported opinion. Reg. § 1.501(c)(3)-1(d)(3)(i). ... The documents that petitioner presents to the public through Mr. Matthews are full of unsupported opinions and distorted facts. Petitioner’s presentations and documents use inflammatory language and emotional and irrelevant statements. Because petitioner’s activities appear principally to involve the presentation to the public of unsupported opinions, petitioner’s activities do not further educational purposes under the operational test. On the record before us, petitioner does not qualify for tax-exempt status under § 501(c)(3) as an educational organization.

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