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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, and
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