- 6 - him as part of his compensation, to the extent used by him to rent or provide a home. The accompanying regulations provide that the rental allowance must be provided as remuneration for ministerial services. See sec. 1.107-1(a), Income Tax Regs. Such services include the ministration of sacerdotal functions; the conduct of religious worship; and the control, conduct, and maintenance of religious organizations, under the authority of a religious body constituting a church. See sec. 1.1402(c)- 5(b)(2), Income Tax Regs. Respondent's only contention regarding section 107 is that FOL is not a "church" and, therefore, Ray and Larry were not ministers performing services under the authority of a church. We disagree. The term "church" is not defined in section 107 or the regulations thereunder. Nevertheless, we have previously stated: To classify a religious organization as a church under the Internal Revenue Code, we should look to its religious purposes and, particularly, the means by which its religious purposes are accomplished. * * * At a minimum, a church includes a body of believers or communicants that assembles regularly in order to worship. When bringing people together for worship is only an incidental part of the activities of a religious organization, those limited activities are insufficient to label the entire organization a church. [Foundation of Human Understanding v. Commissioner, 88 T.C. 1341, 1357 (1987) (Court reviewed); citations and internal quotation marks omitted.] FOL had a far-ranging ministry that reached its members through television and radio broadcasts, written publications, andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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