American Guidance Foundation v. United States

490 F. Supp. 304 (1980)

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American Guidance Foundation v. United States

United States District Court for the District of Columbia
490 F. Supp. 304 (1980)

Facts

The American Guidance Foundation (AGF) (plaintiff) was originally chartered in 1972 as an educational organization. In 1974, AGF designated itself as a church by unanimous consent of its directors, who were Robert Seyfried and several members of his immediate family. Seyfried, who was employed as a public-school teacher but had graduated from Philadelphia College of the Bible in the 1950s, was designated as AGF’s only “Christian Worker.” AGF’s services were held in the Seyfried home, and AGF’s only members were members of the Seyfried family. AGF advertised in the Philadelphia Yellow Pages and used a recorded religious message on a telephone answering machine. AGF did not make significant efforts to convert others or to extend its membership beyond the Seyfried family. The United States Internal Revenue Service (IRS) (defendant) originally classified AGF as an exempt religious organization under §§ 501(c)(3) and 509(a) of the Internal Revenue Code. AGF sought to be reclassified as a church, and the IRS denied the request. AGF exhausted its administrative remedies and brought an action against the IRS. AGF and the IRS filed cross-motions for summary judgment.

Rule of Law

Issue

Holding and Reasoning (Gesell, J.)

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