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IRS Denies Tax Exemption to Christian Group, Associates Bible With GOP

Christians Engaged is appealing the Internal Revenue Service's denial of its application for 501(c)(3) tax-exempt status. (Photo: Zach Gibson/Getty Images)

A top Internal Revenue Service official told a Christian group that “Bible teachings are typically affiliated” with the Republican Party as a rationale for denying its application for tax-exempt status. 

The Texas-based Christians Engaged filed an appeal on Wednesday to the IRS’ denial, objecting to the tax agency’s assertion that it is partisan. 

In a May 18 denial letter, IRS Exempt Organizations Director Stephen A. Martin said Christians Engaged is involved in “prohibited political campaign intervention” and “operate[s] for a substantial non-exempt private purpose and for the private interests of the [Republican Party].”

A “legend” at the top of the letter shows nine letters of the alphabet being used as shorthand to represent something. In this letter’s example, oddly, “D” represented “Republican.” 

“Specifically, you educate Christians on what the Bible says in areas where they can be instrumental, including the areas of sanctity of life, the definition of marriage, biblical justice, freedom of speech, defense, and borders and immigration, U.S. and Israel relations,” Martin wrote. “The Bible teachings are typically affiliated with the D party and candidates. This disqualifies you from exemption under lRS Section 50I(c)(3).” 

Christians Engaged first applied for tax-exempt status in late 2019. First Liberty Institute, a religious freedom public interest law firm, is representing the Christian group in its appeal. 

“We just want to encourage more people to vote and participate in the political process,” Christians Engaged President Bunni Pounds said in a statement. “How can anyone be against that?”

The IRS’ characterization of the Bible might be inconsistent with that of Democratic President Joe Biden, said Lea Patterson, counsel for First Liberty Institute. 

“The IRS states in an official letter that Biblical values are exclusively Republican. That might be news to President Biden, who is often described as basing his political ideology on his religious beliefs,” Patterson said in a statement. 

Patterson appeared to make a vague reference to the tax-exempt unit that was at the center of the IRS targeting scandal during the Obama administration. The ruling also comes amid Biden’s push for an $80 billion expansion of the IRS over 10 years, and the latter could be complicated if the tax agency appears to be more politicized. 

“Only a politicized IRS could see Americans who pray for their nation, vote in every election, and work to engage others in the political process as a threat,” Patterson said. “The IRS violated its own regulations in denying tax-exempt status because Christians Engaged teaches biblical values.”

In its administrative appeal, Patterson contends the IRS made three legal errors: 

By finding that Christians Engaged does not meet the operational test, Director Martin errs in three ways: 1) he invents a nonexistent requirement that exempt organizations be neutral on public policy issues; 2) he incorrectly concludes that Christians Engaged primarily serves private, nonexempt purposes, rather than public, exempt purposes because he thinks its beliefs overlap with the Republican Party’s policy positions; and 3) he violates the First Amendment’s Free Speech, and Free Exercise, and Establishment clauses by engaging in both viewpoint discrimination and religious discrimination.

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