Tax Planning and Compliance for Tax-Exempt Organizations, 2024 Cumulative Supplement, 6th Edition

CHAPTER 1Distinguishing Characteristics of Tax‐Exempt Organizations

• CHAPTER 1.3
• CHAPTER 1.4 Role of the Internal Revenue Service
• CHAPTER 1.5 Suitability as an Exempt Organization

p.4. Add after third paragraph:

The Christ Ambassadors Church was not recognized at tax‐exempt (c)(3) organization by the IRS or the Tax Court. The available descriptions of its activities and modest amount of money involved make one wonder whether there is more to this case than reported. The activities reported on Form 990 included:

• “Assisting individuals with therapy, food pantry, group therapy assistance, individual with therapy, food pantry, group therapy, and after school tutoring to help the less privileged.” (Part II, line 1)
• “Assistance to the public by providing food and medical assistance to the less fortunate and mentally retarded patients in Las Vegas Nevada.” (Schedule O)
• The organization claims public charity status as a church. Schedule A, Part I, box 1. Petitioner operated the 501(c)(3) exempt organization as a church to assist the community with spiritual and other needs.

Christ Ambassadors Church operated a behavioral health clinic. Donations and monies from the behavioral health clinic were used to, among other things, operate the church, bring congregants to and from church events, and purchase food and necessities for the homeless and hungry of the greater Las Vegas, Nevada area.

The IRS's revocation letter said, “Our adverse determination as to your exempt status was ...