Church of Spiritual Technology, Plaintiff-appellant, v. the United States, Defendant-appellee, 991 F.2d 812 (Fed. Cir. 1993)

The Church of Spiritual Technology appeals the judgment of the United States Court of Federal Claims, 26 Cl.Ct. 713 (1992), sustaining the decision of the Commissioner of Internal Revenue that it was not entitled to tax-exempt status under I.R.C. § 501(c) (3) (1982). On the basis of the reasoning set out in the opinion of the Court of Federal Claims, we conclude that the Church of Spiritual Technology did not carry its burden of proving that it is both organized and operated exclusively for tax-exempt purposes, Treas.Reg. § 1.501(c) (3)-1(d) (1) (i) (a), and that it therefore did not establish its eligibility under I.R.C. § 501(c) (3). We affirm.