Universal Life Church, Inc. v. Commissioner Internal Revenue Service

50 F.3d 18 75 A.F.T.R.2d 95 -1521 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. UNIVERSAL LIFE CHURCH, INC., Petitioner-Appellant, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 93-70716. United States Court of Appeals, Ninth Circuit. Submitted Feb. 17, 1995. * Decided March 1, 1995. Before: FLETCHER, PREGERSON, and RYMER, Circuit Judges. 1 MEMORANDUM ** 2 The Universal Life Church, Inc., (ULC) appeals a Tax Court decision on the amount of back taxes that the ULC owes to the Internal Revenue Service (IRS) for 1977-1980, and seeks attorneys fees and sanctions against the IRS. The IRS revoked the ULC's tax-exempt status in 1984. Although the ULC initially contested the IRS's calculation of owed back taxes in the Tax Court, the ULC and the IRS eventually filed with the Tax Court a stipulated settlement of the amount of owed taxes. On appeal, the ULC contends that the decision of the Tax Court subsequent to the stipulation should be vacated because it…