The Appellate Group

Christiansen v. Tax Commission

Christiansen v. Tax Commission, 2020 UT App 46 (per curiam)


An individual did not file state tax returns for several years. After the Tax Commission informed the individual of the tax deficiencies and the individual responded by demanding that the Commission provide proof that she was required to file a federal tax return, the Commission upheld the deficiency and penalty assessments. The Court of Appeals affirmed, holding:

  • The Commission demonstrated that the individual was required to file a federal tax return and thus was required to file a state tax return. 
  • The individual is not exempt from state taxes because, on her own, she is not eligible for a tax exemption under section 501(c) and there is no support for her assertion that she, as an individual, is entitled to a corporate church’s exemption.

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