Foundation of Human Understanding v. United States

614 F.3d 1383 (2010)

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Foundation of Human Understanding v. United States

United States Court of Appeals for the Federal Circuit
614 F.3d 1383 (2010)

Facts

The United States Internal Revenue Service (IRS) (defendant) recognized the Foundation of Human Understanding (foundation) (plaintiff) as a tax-exempt private foundation beginning in 1965. In 1970, the foundation sought recognition as a church under § 170(b)(1)(A)(i) of the Internal Revenue Code, and the IRS determined instead that the foundation qualified as a publicly supported organization. Later, the foundation renewed its request to be recognized as a church, and again the IRS denied the request. The foundation appealed, and the United States Tax Court ruled in favor of the foundation. However, in the years following that decision, the foundation underwent several changes. In 2001, the IRS began an inquiry for the years 1998 through 2000. During that time, the foundation did not hold regular services at any single location but rather held 21 seminars throughout the United States. The foundation also operated an electronic ministry, broadcasting sermons over the radio and Internet at prescribed times. Listeners could call and interact with clergy over the phone during the broadcasts. The IRS determined that the foundation would retain its § 501(c)(3) status but the church status would be revoked. The foundation appealed again, and the United States Court of Federal Claims ruled in favor of the IRS. The foundation appealed.

Rule of Law

Issue

Holding and Reasoning (Bryson, J.)

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