# Chapman v. Commissioner

> United States Tax Court · June 21, 1967 · 48 T.C. 358

URL: https://www.frixlaw.com/law-library/cases/4480558

## Case

- **Full name:** Vaughn v. Chapman and Mildred E. Chapman v. Commissioner of Internal Revenue
- **Court:** United States Tax Court
- **Decided:** June 21, 1967
- **Citations:** 48 T.C. 358; 1967 U.S. Tax Ct. LEXIS 86
- **Precedential status:** Published
- **Opinion:** Dissent by Dawson
- **Judges:** Fay,Raum,Dawson,Tietjens,Simpson,Tannenwald,Hoyt
- **Cited by:** 56 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4480558

## Opinion text

DawsoN, J., concurring: I agree with the conclusions in this case, but I would like to add the following comments.
I think the Missionary Dentist is not a “church” within the definition of that term as implied in section 1.511-2(a) (3) (ii), Income Tax Regs., which seems to me appropriate and reasonable. Cf. De La Salle Institute v. United States, 195 F. Supp. 891, 900-906 (N.D. Cal., 1961). To be a “church” a religious organization must engage in “the ministration of sacerdotal functions and the conduct of religious worship” in accordance with “the tenets and practices of a particular religious body.” The Missionary Dentist, however worthy its cause and service might be, simply does not conduct religious worship according to the “tenets and practices of a particular religious body.” It is interdenominational. It is not affiliated with any particular religious body. Its purpose is not to propagate the tenets or beliefs of a specific religious group. Moreover, proof is lacking as to the ministration of sacerdotal functions by members of the organization. Consequently, I believe it fails to qualify as “a church or a convention or association of churches” within the ordinary meaning of those terms.
TietjeNS and SjmpsoN, //., agree with this concurring opinion.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4480558. Public record. Not legal advice.