[7.8.2] Exempt Organizations Technical Guidelines Handbook
(3.6 Religion or Advancement of Religion) (The IRS no longer provides this on the internet)

[7.8.2] 3.6 (02-23-1999) Religion or Advancement of Religion

1. IRC 501(c)(3) provides for the exemption of organizations organized and operated exclusively for "religious" purposes. Because activities often serve more than one purpose, an organization that is "advancing religion" within the meaning of Reg. 1.501(c)(3)-1(d)(2) may also qualify under IRC 501(c)(3) as charitable or educational organization.

[7.8.2] 3.6.1 (02-23-1999) Constitutional Considerations

1. The First Amendment to the United States Constitution provides that Congress shall make no law respecting an establishment of religion or prohibiting the free exercise thereof. However, the Supreme Court has held that a legislative grant of tax exemption does not violate this prohibition. In Walz v. Tax Commission of the City of New York , 97 U.S. 664 (1970), the Court upheld the constitutionality of property tax exemptions granted by New York City to religious organizations for properties used solely for religious worship. In holding that the exemption of religious organizations, including churches, from tax, is not a law respecting an establishment of religion in violation of the First Amendment, the Court noted that the minimal involvement between church and state created by exemption is far less entanglement than taxation would entail.

[7.8.2] 3.6.2 (02-23-1999) Compliance with Statutory Requirements

1. Any religious organization, including a church, must satisfy the statutory requirements to be exempt under IRC 501(c)(3). As explained by the court in Christian Echos National Ministry. Inc. v. United States , 470 F.2d 849 (10th Cir. 1972), cert . den ., 414 U.S. 864 (1973), in which the court upheld denial of tax exemption to a religious organization engaged in substantial legislative activity, "[i]n light of the fact that tax exemption is a matter of grace rather than right, we hold that the limitations contained in Section 501(c)(3) withholding exemption from nonprofit corporations [that engage in substantial lobbying] do not deprive Christian Echoes of its constitutionally guaranteed right of free speech. The taxpayer may engage in all such activities without restraint, subject, however, to withholding of the exemption, or, in the alternative, the taxpayer may refrain from such activities and obtain the privilege of exemption."
2. Exemption from state or local taxation is neither conclusive nor relevant to the determination whether an organization is operated exclusively for religious purposes under federal tax law. Universal Life Church v. U.S. , 721 USTC 9467 (E.D. Cal. 1972).

[7.8.2] 3.6.3 (02-23-1999) Burden of Proof

1. As noted by the court in Church of Spiritual Technology v. United States , 26 Cl. Ct. 713 (1992), which upheld denial of an organization's application for recognition of exemption, in demonstrating their entitlement to exemption, churches and other religious organizations are subject to the same burden of proof requirements as other organizations.
2. The court in Church of Spiritual Technology cited a long line of authority holding that the applicant bears the burden of showing it is entitled to exemption. In Harding Hospital, Inc. v. United States , 505 F.2d 1068, 1071 (6th Cir. 1974), the court stated that "[i]ncome tax exemption must be strictly construed, with any doubts to be resolved in favor of the taxing entity. Consequently, determinations of the Commissioner are presumed correct."
3. Similarly, the court cited Welch v. Helvering , 190 U.S. 111, 115 (1933), and modern cases following its stricture that "[P]laintiff thus bears the burden of proving its entitlement to an exemption."See also , Bubbling Well Church of Universal Love, Inc. v. Commissioner , 670 F.2d 104, 106 (9th Cir. 1981); Freedom Church of Revelation v. United States , 588 F. Supp. 693, 696 (D.D.C. 1984).

[7.8.2] 3.6.4 (02-23-1999) Validity of Religious Belief

1. In making a determination whether a religious organization qualifies for exemption under IRC 501(c)(3), the Internal Revenue Service cannot pass judgment on the merits of the applicant's asserted religious belief.
2. Accordingly, proof of entitlement to exemption does not include proving the validity of the religious doctrines or beliefs of the applicant or its members. It is the government's duty to "make room for as wide a variety of beliefs and creeds as the spiritual needs of man deem necessary."Zorach v. Clausen , 343 U.S. 306 (1952).
3. This concept is also discussed in U.S. v. Ballard , 322 U.S. 78 (1943), in which the Court stated "The Fathers of the Constitution were not unaware of the varied and extreme views of religious sects, of the violence of disagreement among them, and of the lack of any one religious creed on which all men would agree. They fashioned a charter of government which envisaged the widest possible toleration of conflicting views...The religious views espoused by respondents might seem incredible, if not preposterous, to most people. But if those doctrines are subject to trial before a jury charged with finding their truth or falsity, then the same can be done with the religious beliefs of any sect. When the triers of fact undertake that task, they enter a forbidden domain."

[7.8.2] 3.6.5 (02-23-1999) Religious Belief Defined

1. The term "religious" as used in IRC 501(c)(3) is not subject to precise definition. The leading interpretation of the term was made by the Supreme Court in United States v. Seeger , 380 U.S. 163 (1965), in which the Court interpreted the phrase "religious training and belief" as used in the Universal Military Training and Service Act, 50 U.S.C. section 456 (j), in determining an individual's eligibility for exemption from military service on religious grounds. The Court formulated the following definition: "A sincere and meaningful belief which occupies in the life of its possessor a place parallel to that filled by the God of those admittedly qualifying for the exemption comes within the statutory definition."
2. The Court elaborated upon the Seeger definition in Welsh v. United States , 398 U.S. 33 (1970), stating that "[i]f an individual deeply and sincerely holds beliefs that are purely ethical or moral in source and content but that nevertheless impose upon him a duty of conscience to refrain from participating in any war at any time, those beliefs certainly occupy in the life of that individual a place parallel to that filled by... God in the lives of traditionally religious persons." Thus, religious beliefs include many beliefs (for example, Taoism, Buddhism, and Secular Humanism) that do not posit the existence of a Supreme Being in the conventional sense.

[7.8.2] 3.6.6 (02-23-1999) Actions Distinguished from Beliefs

1. The constitutional protections afforded religious beliefs do not prevent government from regulating conduct or actions when it has a compelling interest to do so. Thus, the First Amendment does not prevent the government from requiring compliance with general laws designed to effectuate an important governmental policy or objective even though compliance may be contrary to an individual's sincerely-held religious beliefs.
2. In Reynolds v. United States , 98 U.S. 145 (1878), the Court upheld a law passed by Congress that made the practice of polygamy by persons residing in United States territories a crime. The Court interpreted the constitutional prohibition in this way: "Congress was deprived of all legislative power over mere opinion, but was left free to reach actions which were in violation of social duties or subversive of good order." Finding that polygamy had long been considered an offense against society in all the states of the union, the Court held that the statute under consideration was constitutional and valid as prescribing a rule of action for all those residing in the territories. In holding that religious belief did not except persons from operation of the statute, the Court said: "While they [laws] cannot interfere with mere religious belief and opinions, they may with practices."
3. In Cantwell v. Connecticut , 310 U.S. 296 (1940), the Court endorsed Reynolds , stating that "the [First] Amendment embraces two concepts, freedom to believe and freedom to act. The first is absolute but, in the nature of things, the second cannot be."SeealsoDavis v. Beason , 133 U.S. 33 (1890), and Mormon Church v. United States , 136 U.S. 1 (1890), where the Court grappled with the same issue. While continuing to affirm the right of freedom of religious belief, the Court nevertheless held that legislation for the punishment of actions "inimical to the peace, good order and morals of society" did not violate the First Amendment.
4. A notable recent application of this doctrine is Bob Jones University v. United States , and Goldsboro Christian Schools v. United States , 461 U.S. 574 (1983), in which the Supreme Court upheld revocation of the exemption under IRC 501(c)(3) of religious and educational institutions on the grounds that its religiously motivated policy forbidding interracial dating violated a fundamental public policy against racial discrimination. The Court concluded that educational institutions that practice racial discrimination based on religious beliefs are not charitable in the generally accepted legal sense and thus do not qualify for federal tax exemption.

[7.8.2] 3.6.7 (02-23-1999) Substantial Nonexempt Purposes

1. An organization's activities in furtherance of a religious belief must serve exclusively exempt purposes. See Reg. 1.501(c)(3)-1(c)(1). If the organization's activities promote a substantial nonexempt purpose, exemption under IRC 501(c)(3) is precluded.
2. In one case, the Tax Court held that an organization dominated by one individual was not exempt as a religious organization because its purpose was to carry on the founder's personal feud with a local newspaper. The court did not examine the validity or sincerity of the beliefs held. Rather, it found that the actual activities had little relation to the observance of those beliefs. Puritan Church of America , 10 T.C.M. 485 (1951), aff'd per curiam , 209 F.2d 306 (D.C. Cir. 1953), cert . den ., 350 U.S. 810 (1955).
3. In First Libertarian Church v. Commissioner , 74 T.C. 396 (1980), the court held that an organization that was the outgrowth of a supper club and whose primary activities were holding meetings before supper, sponsoring the supper club, and publishing a newsletter did not qualify for exemption under IRC 501(c)(3). The organization failed to show that it successfully segregated the clearly social and political aspects of its supper club meetings and its publication from its stated purpose of furthering its religious doctrine of "ethical egoism."
4. Religious organizations that engage in substantial legislative activity are disqualified from tax exemption regardless of the motivation or purpose of that activity. Christian Echoes National Ministry, Inc. v. U.S. , 470 F.2d 849 (10th Cir. 1972), cert . den ., 414 U.S. 864 (1973).
5. In The Schoger Foundation v. Commissioner , 76 T.C. 380 (1981), an organization operating a religious retreat facility did not qualify for exemption under IRC 501(c)(3) because it failed to show that the retreat facility was operated exclusively for religious purposes. Although the organization's mountain lodge offered guests religious, recreational, and social activities, none of were regularly scheduled or required. The court concluded that the organization had not met its burden of proof to show that the lodge was operated primarily for an exempt religious purpose and that the recreational and social activities at the lodge were only incidental to a religious purpose.
6. The Tax Court held an organization formed to arrange for the construction of housing for sale to individuals associated with a religious denomination to be exempt under IRC 501(c)(3) in Janaluska Assembly Housing Inc. v. Commissioner , 86 T.C. 1114 (1986). The housing was to be constructed on the grounds of a retreat center owned by a conference of the United Methodist Church. The Service concluded that the housing would substantially further the nonexempt purpose of providing recreational and vacation opportunities to the purchasers. In a declaratory judgment action, the Tax Court concluded that because only active participants in the religious activities conducted at the center would be permitted to purchase the housing, the organization was organized and operated exclusively to further religious purposes.
7. An organization will not qualify for exemption under IRC 501(c)(3) if its net earnings inure to the benefit of private shareholders or individuals.
1. In The Founding Church of Scientology v. United States , 412 F.2d 1197 (Ct. Cl. 1969), cert . den ., 397 U.S. 1009 (1970), the court, without considering the organization's beliefs, held that it did not qualify for exemption under IRC 501(c)(3) because its net earnings inured to the organization's founder and members of his family. SeealsoPeople of God Community v. Commissioner , 75 T.C. No. 8 (1980); Bubbling Well Church of Universal Love v. Commissioner , 74T.C. 531 (1980); Unitary Mission Church of Long Island, Inc. v. Commissioner , 74 T.C. 507 (1980); Western Catholic Church v. Commissioner , 73 T.C. 196 (1979); The Basic Unit Ministry of Schurig v. U. S. , 81-1 USTC S9188 (D.D.C. 1981); Church of the Transfiguring Spirit. Inc. v. Commissioner , 76 T.C. 1 (1981); Church of Scientology of California v. Commissioner , 823 F.2d 1310 (9th Cir. 1987).
2. In Basic Bible Church v. Commissioner , 74 T.C. 846 (1980), the organization's founder and his wife executed vows of poverty and transferred all their possessions and income to the organization on the condition that it qualified under IRC 501(c)(3). The founder controlled all financial decisions of the organization. The court found that a substantial purpose of the organization was to serve the private interests of the founder and his wife. Over 96 percent of the contributions the organization received (mostly from the founder and his wife) were spent on the founder's and his wife's subsistence, their unsubstantiated travel, and upkeep and utilities of their home, which was labeled their "parsonage." Less than one percent of contributions were spent for direct church related expenses. Accordingly, the court held that the organization did not qualify under IRC 501(c)(3). SeealsoThe Church in Boston v. Commissioner , 71 T.C. 102 (1978); and Southern Church of Universal Brotherhood Assembled v. Commissioner , 74 T.C. No. 89 (1980).
3. In Beth-El Ministries. Inc. v. United States , 79-2 USTC S9412, an organization whose members donated all their possessions and, if employed outside the organization, their salaries, to the organization, and which provided its members benefits in the form of food, clothing, shelter, medical care, recreational facilities, and educational services, was held not to be exempt as a religious organization. The court concluded that private benefits inured to the organization's members because the organization paid their living expenses. SeealsoMartinsyille Ministries, Inc. v. United States , 80-2 USTC S9710 (D.D.C. 1979). ButseeAlive Fellowship of Harmonious Living v. Commissioner , T.C. Memo. 1984-87. The Tax Court held that no inurement resulted when an organization's members received benefits on the basis of need. However, in approving this "unconventional" compensation arrangement, the court based its decision on the fact that members received less than modest assistance that did not exceed the value of the required services that they performed.
8. For a discussion of the attributes that are necessary for a religious organization to be classified as a church or a convention or association of churches, see Chapter 2 of IRM 7752, Private Foundations Handbook.

[7.8.2] 3.6.8 (02-23-1999) Religious Publishing

1. Publishing literature is an important method of disseminating religious views. However, publishing may also be a business operating in competition with commercial enterprises. The Service has held that publishing and distributing a monthly newspaper carrying church news of interdenominational interest accomplishes a charitable purpose by contributing to the advancement of religion. In that case subscriptions were obtained through individual churches and church associated groups and revenues did not cover the costs of operation. Rev. Rul. 68-306, 1968-1 C.B. 257.
2. In a Tax Court case, an organization sold a large volume of literature to the general public by mail. Some of the literature had little or no connection to the beliefs held by the organization. The surrounding circumstances tended to show that the individual who dominated the organization regarded the enterprise "simply as a money making operation." The court held that this was not a religious organization, but rather a trade or business. Foundation for Divine Meditation, Inc. , 24 T.C.M. 411 (1965), affirmed sub. nom. M.E. Parker v. Commissioner , 365 F.2d 792 (8th Cir. 1966), cert . denied , 385 U.S. 1026 (1967).
3. In cases where religious literature is published by an organization to promote its beliefs, the activity may further exclusively religious purposes even though it produces an operating profit. Saint Germain Foundation , 26 T.C. 648 (1956); Unity School of Christianity , 4 B.T.A. 61 (1926). See alsoPulpit Resource v. Commissioner , 70 T.C. 594 (1978), in which the court reversed the Service's denial of exemption to an organization that sold a publication containing prepared sermons for use by ministers.
4. However, in Scripture Press Foundation v. United States , 285 F.2d 800 (1961), cert . den ., 363 U.S. 985 (1962), a separately organized publishing corporation sold a large volume of religious literature, periodicals, and Sunday school supplies at a substantial profit was held not exempt. The court found that operating profits and accumulated earnings were disproportionately large and there was no clear purpose to further any particular religious beliefs. The general character of the operation was that of a commercial publishing house catering to religious customers. Thus, the court concluded it was a trade or business and not exempt. The existence of a modest program of expenditures for religious and educational purposes unconnected with the publishing did not have a decisive effect. SeealsoChristian Manner International v. Commissioner , 71 T.C. 661 (1979).
5. One case places a great weight on the existence of an operating profit and a commercial pricing pattern. In Fides Publishers Association v. United States , 263 F. Supp. 924 (1967), a corporate publisher of religious books priced at commercial levels that showed moderate but consistent operating profits was held not to be exempt. The court said that although the "publishing activities further the exempt purpose of educating the lay apostolate," nevertheless, there was a substantial nonexempt purpose-- "the publication and sale of religious literature at a profit."
6. In another case, an organization that published religious literature was held to no longer qualify as tax exempt in view of an abrupt increase in salaries of top personnel of the organization's press, a large amount of accumulated profits, and the fact that the press was in direct competition with a number of commercial publishers. The facts showed that the organization's primary purpose was to operate as a commercial business producing net profits. Incorporated Trustees of the Gospel Workers Society v. U.S. , 520 F. Supp. 374 (D.D.C. 1981).
7. On the other hand, the Third Circuit Court of Appeals upheld the exempt status of another religious publishing organization, concluding that its accumulation of capital for physical expansion and its increased profit due to unexpected increases in popularity of one of the publisher's authors did not show a substantial non-exempt purpose. Presbyterian and Reformed Publishing Co. v. Commissioner , 743 F.2d 148 (3rd Cir. 1984).

[7.8.2] 3.6.9 (02-23-1999) Religious Broadcasting

1. Broadcasting is an activity analogous to publishing. In Rev. Rul. 68-513, 1968-2 C.B. 212, a religious broadcasting station was held exempt under IRC 501(c)(3), where broadcast time was devoted to worship services and other programs having religious content. Although the station was operated on a commercial license, it did not sell commercial or advertising time.
2. Rev. Rul. 68-563 was amplified in Rev. Rul. 78-385, 1978-2 C.B. 174, which held a religious and educational television station exempt under IRC 501(c)(3) even though it devoted an insubstantial amount of broadcast time to commercially sponsored programs. However, the commercially sponsored programs are unrelated trade or business under IRC 513.

[7.8.2] 3.6.10 (02-23-1999) Commercial vs. Religious Activities

1. A nonprofit organization that supervises the preparation and inspection of food products prepared commercially to insure the compliance of individual members with the tenets and dictates of a particular religion was held to be accomplishing a charitable purpose by engaging in an activity that advances religion and thus the organization is exempt under IRC 501(c)(3) in Rev. Rul. 74-575, 1974-2 C.B. 161.
2. Similarly, a nonprofit organization formed to compile genealogical research data on its family members in order to perform religious ordinances in accordance with the precepts of the religious denomination was held to be advancing religion. Rev. Rul. 71-580, 1971-2 C.B. 235.
3. Rev. Rul. 75-282, 1975-2 C.B. 201 held that an organization, formed and controlled by an exempt conference of churches, that borrows funds from individuals and makes mortgage loans at less than the commercial rate of interest to affiliated churches to finance the construction of church buildings qualifies for exemption. By operating under the close supervision and control of the parent church conference, the organization was considered to be advancing religion by carrying out an integral part of the activities of the parent, i.e., aiding member churches in obtaining facilities for their religious purposes.
4. Rev. Rul. 77-377, 1977-2 C.B. 192, reached a contrary result concerning a nonprofit organization that arranges and conducts winter-time ocean cruises during which activities to further religious and educational purposes are provided in additional to extensive social and recreational activities. This organization is not operated exclusively for exempt purposes under IRC 501(c)(3).
5. Rev. Rul. 77-430, 1977-2 C.B. 194, held that an otherwise qualifying organization that conducts weekend religious retreats, open to individuals of diverse Christian denominations, at a rural lakeshore site at which the participants may enjoy the recreational facilities in their limited amount of free time and that charges no fees qualifies for exemption under IRC 501(c)(3) as an organization operated exclusively for religious purposes. This organization is clearly distinguishable from the one in Rev. Rul. 77-366 because the facts show the primary emphasis was on religious, not recreational, activities.
6. Rev. Rul. 79-359, 1979-2 C.B. 226, held that an organization whose purpose is to provide traditional burial services that directly support and maintain basic tenets and beliefs of a religion regarding burial of its members is operated exclusively for charitable purposes and is exempt under IRC 501(c)(3).
7. An organization that operated a medical aid plan for its church members was held to be furthering the church's religious tenet that members should bear one another's burdens and thus was entitled to exemption under IRC 501(c)(3). Bethel Conservative Mennonite Church v. Commissioner , 84-2 USTC 9195 (CA 7), rev'g 80 T.C. 352 (1983).
8. Compare Living Faith v. Commissioner , 950 F.2d 365 (7th Cir. 1991), aff'g T.C.M. 1990-484, in which an organization that operated vegetarian restaurants and health food stores in a manner consistent with the religious beliefs of the Seventh-Day Adventist religion did not qualify for recognition of exemption under IRC 501(c)(3). The court concluded its operations evidenced a substantial nonexempt commercial purpose.

[7.8.2] 3.6.11 (02-23-1999) Mail Order Churches

1. The term "mail order church" refers to organizations set up pursuant to "church charters" purchased through the mail from organizations that claim that the charters and other "ministerial credentials" can be used to reduce or eliminate an individual's federal income tax liability. Although a "mail order church" is not precluded from exemption, because it is possible for one to be organized operated exclusively for religious purposes, Service experience, as reflected in numerous court decisions, has shown that many are operated for the private benefit of those who control the organization. See IRM 7.6.2, for procedures regarding coordination with Examination function of IRC 170(c) deduction cases and assignment of income cases; and also for a general discussion of examination procedures for mail order churches; churches or conventions or associations of churches; and a discussion of IRC 7611, which sets forth certain restrictions on the examination of churches.
2. Service position regarding a common form of operation for many mail order churches is set forth in Rev. Rul. 81-94, 1981-1 C.B. 330. In Rev. Rul. 81-94 a professional nurse founded an organization under the name of ABC Church after purchasing a "certificate of ordination" from an organization selling such certificates and church charters. The nurse was the organization's minister, director, and principal officer. The nurse executed a vow of poverty and transferred all of her assets, including a home and an automobile, and income to the organization. The organization also assumed all of her liabilities, including a home mortgage and credit card balances. The organization paid all her living expenses, and she continued to use the house and automobile for personal purposes. Rev. Rul. 81-94 concludes that, based on these facts, the organization does not qualify for exemption under IRC 501(c)(3) because it operates to serve the private interests of a designated individual rather than a public interest.
3. Numerous court cases have held that, in situations similar to that described in Rev. Rul. 81-94, an organization that serves the private interests of a designated individual rather than a public interest does not qualify for exemption under IRC 501(c)(3). See , for example, Basic Bible Church v. Commissioner , 74 T.C. 846 (1980); Church of the Transfiguring Spirit, Inc. v. Commissioner , 76 T.C. 1 (1981); People of God Community v. Commissioner , 75 T.C. 127 (1980); The Southern Church of Universal Brotherhood Assembled, Inc. v. Commissioner , 74 T.C. 1223 (1980); Bubbling Well Church of Universal Love v. Commissioner , 74 T.C. 531 (1980); and Unitary Mission Church of Long Island v. Commissioner , 74 T.C. 507 (1980); aff'd , 647 F. 2d 163 (2d Cir. 1981).
4. On a related issue, the Service has denied a charitable contribution deduction under IRC 170 for amounts contributed by an individual to an organization formed under the name of the ABC Church but operated for the individual's private benefit. See Rev. Rul. 78-232, 1978-1 C.B. 69. Numerous court cases have also held that, in situations similar to the one described in Rev. Rul. 78-232, a charitable contribution deduction under section 170 was properly denied by the Service. See , for example, McGahen v. Commissioner , 76 T.C. No. 41 (March 26, 1981); Hall v. Commissioner , T.C.M. 1981-143; Baker v. Commissioner , T.C.M. 1980-367; Manson v. Commissioner , T.C.M. 1980-315, aff'd , 628 F. 2d. 1353 (5th Cir. 1980); Abney v. Commissioner , T.C.M. 1980-27; Push v. Commissioner , T.C.M. 1980-4; Heller v. Commissioner , T.C.M. 1978-149; and Clippinger v. Commissioner , T.C.M. 1978-107.
5. In many situations where the organization selling the church charters and ministerial credentials has been recognized as exempt under IRC 501(c)(3) (but has not received a group exemption), the organization purchasing the charter claims that it is covered by the selling organization's exempt status. This argument was made in Basic Bible Church, discussed above, where the petitioner contended that as an auxiliary of the Basic Bible Church, it shared that organization's tax exempt status (The organization had not received a group ruling). The court concluded, however, that the petitioner was legally separate and distinct from the parent church and, therefore, had to qualify for exemption under IRC 501(c)(3) on its own merits. See alsoUnited States v. Toy National Bank , 79-1 USTC P9344 (N.D.lowa 1979), and Brown v. Commissioner , T.C.M. 1980-553, which held that organizations that had obtained a charter from the Universal Life Church, Inc. (ULC) were not covered by that organization's individual exemption. The courts in these cases concluded that because ULC had an individual rather than a group exemption, the chartered organizations had to qualify for exemption on their own merits.

[7.8.2] 3.6.12 (02-23-1999) Digests of Precedent Rulings

1. Coffee house-- A nonprofit organization formed by local churches to operate a supervised facility known as a "coffee house," in which persons of college age are brought together with church leaders, educators and leading businessmen of the community for discussions and counseling on religion, current events, social, and vocational problems was held to be advancing religion and thus exempt as a charitable organization. Rev. Rul. 68-72, 1968-1 C.B. 250.
2. Religious publishing-- A nonprofit organization that publishes a newspaper primarily devoted to news, articles, and editorials relating to church and religious matters is exempt. Rev. Rul. 68-306, 1968-1 C.B. 257.
3. Religious broadcasting-- A nonprofit religious broadcasting station that does not sell commercial or advertising time is exempt under IRC 501(c)(3) even though it operates on a commercial license. Rev. Rul. 68-563, 1968-2 C.B. 212.
4. Genealogical research-- A nonprofit organization formed to compile genealogical research data on its family members in order to perform religious ordinances in accordance with the precepts of the religious denomination to which family members belong is advancing religion and thus exempt. Rev. Rul. 71-580, 1971-2 C.B. 235.
5. Supervision and inspection of commercially prepared food products-- A nonprofit organization that supervises the preparation and inspection of food products prepared commercially in a particular locality to insure that they satisfy the dietary rules of a particular religion, thereby assisting the individual members of the religion to comply with its tenets and dictates, qualifies for exemption. Rev. Rul. 74-575, 1974-2 C.B. 161.
6. Mortgage loans to conference churches--An organization formed and controlled by an exempt conference of churches that borrows funds from individuals and makes mortgage loans at less than the commercial rate of interest to affiliated churches to finance the construction of church buildings qualifies for exemption. Rev. Rul. 75-282, 1975-2 C.B. 201.
7. Missionary housing-- An organization established to provide temporary low-cost housing and related services for missionary families on furlough for recuperation or training in the U.S. from their assignments abroad is operated exclusively for charitable purposes. Rev. Rul. 75-434, 1975-2 C.B. 205.
8. Religious tours-- A nonprofit organization that arranges and conducts winter cruises during which activities to further religious and educational purposes are provided in addition to extensive social and recreational activities is not operated exclusively for exempt purposes and does not qualify for exemption. Rev. Rul. 77-366, 1977-2 C.B. 192.
9. Religious retreats-- An otherwise qualifying organization that conducts weekend religious retreats, open to individuals of diverse Christian denominations, at a rural lakeshore site at which the participants may enjoy the recreational facilities in their limited amount of free time and that charges no fees is operated exclusively for religious purposes and qualifies for exemption. Rev. Rul. 77-430, 1977-2 C.B. 194.
10. Charitable contribution; benefit to contributors-- An individual who claims to be a minister, forms an organization under the name ABC Church, deposits salary checks for salary earned from outside employment in the organization's bank account, and uses the funds of the account for personal living expenses is not entitled to a charitable deduction under IRC 170 for the amount of the salary checks. Rev. Rul. 78-232, 1978-1 C.B. 69.
11. Religious broadcasting-- A nonprofit organization formed to advance education and religion that broadcasts religious and educational programs for all but an insubstantial amount of its broadcast time from a television station it owns and operates under a commercial license qualifies for exemption under IRC 501(c)(3), even though its remaining broadcast time is devoted to commercially sponsored programs. The commercially sponsored programs, however, are unrelated trade or business under IRC 513. Rev. Rul. 78-385, 1978-2 C.B.
12. Religious burial services-- A nonprofit organization whose purpose is to provide traditional burial services that directly support and maintain basic tenets and beliefs of a religion regarding burial of its members is operated exclusively for charitable purposes and qualifies for exemption. Rev. Rul. 79-359, 1979-2 C.B. 226.
13. Church operated for benefit of founder-- A nonprofit organization formed under the name ABC Church by a professional nurse (who is also the organization's minister, director, and principal officer) that is used as a vehicle for handling the nurse's personal financial transactions is not exempt under IRC 501(c)(3) because it serves the private interests of a designated individual rather than a public interest. Rev. Rul. 81-94, 1981-1 C.B. 330.