Church of Modern Enlightenment v. Commissioner

The Church of Modern Enlightenment (church) (plaintiff) was organized to spread the doctrine of Christian-Buddhism. Richard Engert founded the church and served as one of its trustees, along with his sister and a coworker, Sanford Kleinman. Engert and Kleinman, who were the church’s only two clergymen, worked together at the New York Transit Authority. Neither Engert nor Kleinman had formal religious training or was an ordained minister. Engert donated all the income from his full-time job to the church. He was the church’s only donor and controlled the church’s finances. Engert devoted approximately 25 hours per week to church affairs, plus approximately one and a half hours per week for services and five hours per month for board of directors’ meetings, research, and education. According to the church’s financial report, virtually all the church’s expenses were Engert’s living expenses, including rent, food, and clothing. Services were held at the facilities of another religious institution, and the church used Engert’s apartment in Brooklyn as its office. Membership in the church was open to all who believed in its tenets, but Kleinman and Engert’s sister were the only members of the congregation. There was no evidence the church engaged in evangelical or proselytizing activities to establish a congregation. The church also provided no religious instruction for the young. The commissioner of internal revenue (commissioner) (defendant) denied the church’s application for exemption from income taxation under § 501(c)(3), and the church sought a declaratory judgment that it was entitled to the exemption.