NOTICE: Federal Circuit Local Rule 47.6(b) states that opinions and
       orders which are designated as not citable as precedent shall not
       be employed or cited as precedent.  This does not preclude
       assertion of issues of claim preclusion, issue preclusion, judicial
       estoppel, law of the case or the like based on a decision of the
       Court rendered in a nonprecedential opinion or order.

       (The decision of the Court is referenced in a "Table of Decisions
       Without Reported Opinions" appearing in the Federal Reporter.)

              CHURCH OF SPIRITUAL TECHNOLOGY, Plaintiff-Appellant,
                     The UNITED STATES, Defendant-Appellee.
                                  No. 92-5155.
                United States Court of Appeals, Federal Circuit.
                                 March 29, 1993.
                        Rehearing Denied April 26, 1993.
  26 Cl.Ct. 713.

  **1 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. s 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. s 1.501(c)(3)-1(d)(1)(i)(a), and that it therefore did not
 establish its eligibility under I.R.C. s 501(c)(3).  We affirm.