August 7, 2008 | Read Time: 2 minutes
The Internal Revenue Service has told an organization that says it operates “for the advancement of Christianity and for other charitable purposes” that it does not qualify for a federal tax exemption as a church.
In its application for tax-exempt status, the group said it conducts “street ministry” activities, expects to rent a building to hold indoor services, and might start a religious school for young people.
The group said its board of directors has four members: its pastor, who is the founder and board chairman; his wife, who is the co-chair, secretary, and treasurer; a son, who is assistant secretary; and another son.
In its ruling, the IRS noted that no definition of “church” appears in the tax code. However, the agency and courts have identified several factors that the government can use to decide whether a group is a church for tax purposes.
Among them: the presence of an established congregation served by an ordained ministry and the provision of regular religious services.
But the IRS said the group applying for a tax exemption in this case lacks “all of the significant elements” used to determine that an organization qualifies as a church.
The group did not provide details about its street ministry, its finances, or its plans to recruit members, the Internal Revenue Service said.
“You do not have a group of people who come together on a regular basis and you do not hold regular religious services,” the tax agency said. “Your organization consists of only four members of a single family and you do not even hold regular religious services for those individuals.”
For these and other reasons, the IRS decided the group is not operating as a church or as any kind of charity.
As is its policy, the IRS did not identify the group or people involved in its ruling.
The decision is online.
