IRS Published Taxpayer Determination Letter 202625024

Private letter rulings and published taxpayer determination letters. Native document type is retained separately; a determination letter is not labeled a private letter ruling. These taxpayer-specific releases cannot be used or cited as precedent under 26 USC 6110(k)(3); applicability and current legal force are not independently certified. Keep repeated UILC subjects attached to one actual numbered document. Native kind: determination letter; this is not a private letter ruling.

# Department of the Treasury Internal Revenue Service Tax Exempt and Government Entities

IRS

Date:
03/27/2026
Employer ID number:

Form you must file:

Tax years:

Person to contact:

Release Number: 202625024

Release Date: 6/18/26

UIL Code: 501.03-30

Dear

This letter is our final determination that you don't qualify for exemption from federal income tax under Internal
Revenue Code (IRC) Section 501(a) as an organization described in IRC Section 501(c)(3). Recently, we sent
you a proposed adverse determination in response to your application. The proposed adverse determination
explained the facts, law, and basis for our conclusion, and it gave you 30 days to file a protest. Because we
didn't receive a protest within the required 30 days, the proposed determination is now final.

Because you don't qualify as a tax-exempt organization under IRC Section 501(c)(3), donors generally can't
deduct contributions to you under IRC Section 170.

We may notify the appropriate state officials of our determination. as required by IRC Section 6104(c), by
sending them a copy of this final letter along with the proposed determination letter.

You must file the federal income tax forms for the tax years shown above within 30 days from the date of this
letter unless you request an extension of time to file. For further instructions, forms, and information, visit
www.irs.gov.

We'll make this final adverse determination letter and the proposed adverse determination letter available for
public inspection after deleting certain identifying information. as required by IRC Section 6110. Read the
enclosed Letter 437, Notice of Intention to Disclose - Rulings. and review the two attached letters that show our
proposed deletions. If you disagree with our proposed deletions. follow the instructions in the Letter 437 on how
to notify us. If you agree with our deletions, you don't need to take any further action.

If you have questions about this letter, you can call the contact person shown above. If you have questions
about your federal income tax status and responsibilities, call our customer service number at 800-829-1040
(TTY 800-829-4933 for deaf or hard of hearing) or customer service for businesses at 800-829-4933.

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Sincerely,
Stephen A. Martin
Director, Exempt Organizations
Rulings and Agreements

Enclosures:
Letter 437
Redacted Letter 4034

Redacted Letter 4038

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Department of the Treasury
Internal Revenue Service

IRS

Legend:
M = State
N = Date
P = Date

Date: 02/04/2026

Employer ID number:

Person to contact:

Name:

ID number:

Telephone:

Fax:

UIL:

501.03-30

Dear
:

We considered your application for recognition of exemption from federal income tax under Internal Revenue
Code (IRC) Section 501(a). We determined that you don't qualify for exemption under IRC Section 501(c)(3).
This letter explains the reasons for our conclusion. Please keep it for your records.

Issues

Do you qualify for exemption under IRC Section 501(c)(3)? No, for the reasons stated below.

## Facts

You were incorporated on N in the state of M. Your organizing document states your purpose is to promote and
protect Christian values and principles in the current public culture. There is no further language limiting your
purposes or powers to those recognized as being exclusively within the purview of IRC Section 501(c)(3).

Your Form 1023, Application for Recognition of Exemption Under IRC Section 501(c)(3), submission provided
additional information. Your narrative indicated that you are dedicated to educating, inspiring and empowering
Christians to stand and speak God's truth and love in a culture that has rejected both. Further, you marked "yes"
to the question of whether you would support or oppose candidates in political campaigns in any way. You
replied that you will support candidates in political campaigns who hold to Christian ethics. You also marked
"yes" to the question of whether the organization would attempt to influence legislation. To this you added that
you would educate Christians to vote their values and beliefs.

We requested clarification of your activities. You expounded that you host prayer meetings, events and
outreaches. You will create and distribute resources designed to promote and advance the word of God on
spiritual and moral issues facing this generation. You also intend to form other local chapters. We allowed

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additional time for more information to be submitted but no further details or explanations were provided on
any of your activities.

Your financial data shows all income coming from gifts grants and donations. You reported no expenses.

## Law

Internal Revenue Code Section 501(c)(3) provides for the exemption from federal income tax of organizations
organized and operated exclusively for charitable or educational purposes, no substantial part of the activities of
which is carrying on propaganda, or otherwise attempting to influence legislation (except as otherwise provided
in section 501(h)), and which does not participate in, or intervene in (including the publishing or distributing of
statements), any political campaign on behalf of (or in opposition to) any candidate for public office.

Treasury Regulation Section 1.501(c)(3)-1(a)(1) provides that, to be exempt as an organization described in IRC
Section 501(c)(3), an organization must be both organized and operated exclusively for one or more of the
purposes specified in such section. If an organization fails to meet either the organizational or operational test, it
is not exempt.

Treas. Reg. Section 1.501(c)(3)-1(b)(1) provides that an organization is organized exclusively for one or more
exempt purposes only if its articles of organization limit the purposes of such organization to one or more
exempt purposes and do not expressly empower the organization to engage, otherwise than as an insubstantial
part of its activities, in activities which in themselves are not in furtherance of one or more exempt purposes.

Treas. Reg. Section 1.501(c)(3)-1(c)(1) provides that an organization will be regarded as operated exclusively
for one or more exempt purposes only if it engages primarily in activities which accomplish one or more of
such exempt purposes specified in IRC Section 501(c)(3). An organization will not be so regarded if more than
an insubstantial part of its activities is not in furtherance of an exempt purpose.

Treas. Reg. Section 1.501(c)(3)-1(c)(3)(i) states that an organization is not operated exclusively for one or more
exempt purposes if it is an "action" organization.

Treas. Reg. Section 1.501(c)(3)-1(c)(3)(iii) defines an "action" organization as an organization that participates
or intervenes, directly or indirectly, in any political campaign on behalf of or in opposition to any candidate for
public office. The term "candidate for public office" is defined as an individual who offers himself, or is
proposed by others, as a contestant for an elective public office, whether such office be national, state, or local.
The regulations further provide that activities that constitute participation or intervention in a political campaign
on behalf of or in opposition to a candidate include, but are not limited to, the publication or distribution of
written statements or the making of oral statements on behalf of or in opposition to such a candidate.

Revenue Ruling 2007-41, 2007-25 I.R.B., provides the following guidance on Issue Advocacy vs. Political
Campaign Intervention:

Section 501(c)(3) organizations may take positions on public policy issues, including issues that divide
candidates in an election for public office. However, Section 501(c)(3) organizations must avoid any issue
advocacy that functions as political campaign intervention. Even if a communication does not expressly tell an
audience to vote for or against a specific candidate, an organization is at risk of violating the political campaign
intervention prohibition if there is any message favoring or opposing a candidate. A statement can identify a

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candidate not only by stating the candidate's name but also by other means such as showing a picture of the
candidate, referring to political party affiliations, or other distinctive features of a candidate's platform or
biography. All the facts and circumstances need to be considered to determine if the advocacy is political
campaign intervention.

Revenue Procedure 2025-5, Section 3, states that a determination letter or ruling on exempt status is issued
based solely upon the facts and representations contained in the administrative record. The applicant is
responsible for the accuracy of any factual representations or attestations contained in the application. Section 6
(and its predecessors) provides that a favorable determination letter or ruling will be issued to an organization
only if its application and supporting documents establish that it meets the particular requirements of the section
under which exemption from federal income tax is claimed.

In Universal Life Church, Inc. v. United States, 372 F. Supp. 770 (E.D. Cal. 1974), the court concluded that
"one seeking a tax exemption has the burden of establishing his right to a tax-exempt status."

Pius XII Academy, Inc. v. Commissioner, T.C. Memo. 1982-97, affd. 711 F.2d 1058 (6th Cir. 1983), provides
that an organization must establish through the administrative record that it operates as an exempt organization.
Denial of exemption may be based solely upon failure to provide information describing in adequate detail how
the operational test will be met.

## Application of law

Per Revenue Procedure 2025-5, Section 3, rulings on exempt status are based solely upon the facts and
representations contained in the administrative record. The applicant is responsible to represent the accuracy
and completeness of the information contained in the application submission (administrative record). Section 6
(and its predecessors) provides that a favorable determination letter or ruling will be issued to an organization
only if its submission demonstrates that it meets the particular requirements of the section under which
exemption from federal income tax is claimed. You have not provided such evidence or demonstrated how you
meet the standards of IRC Section 501(c)(3).

IRC Section 501(c)(3) sets forth two main tests for qualification for exempt status. As stated in Treas. Reg.
1.501(c)(3)-1(a)(1), an organization must be both organized and operated exclusively for purposes described in
IRC Section 501(c)(3). The purpose stated in your organizing document does not limit your purposes
exclusively to those recognized under IRC Section 501(c)(3). As a result, you have not satisfied the
organizational test described in Treas. Reg. Section 1.501(c)(3)-1(b)(1)(i).

By participating in or intervening in political campaigns on behalf of or in opposition to any candidate for
public office you meet the definition of an "action organization" within the meaning of the regulations. See
Treas. Reg. Section 1.501(c)(3)-1(c)(3)(i)-(iii). On your Form 1023, you affirmed that you would support or
oppose candidates in political campaigns and that you would attempt to influence legislation. Specifically, you
indicated that you would take part in political campaign intervention by endorsing specific candidates that are in
line with your beliefs. You also stated that you would educate Christians to vote their values and beliefs. As
noted in Rev. Rul. 2007-41, these activities point to the fact that you are participating in political campaign
intervention. You provided no additional facts or details to consider. Thus, you have failed to establish that you
are not an action organization. Accordingly, pursuant to Treas. Reg. Section 1.501(c)(3)-1(c)(3)(i), you are not
operated exclusively for one or more exempt purposes.

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Pius XII Academy, Inc. found that failure to provide information describing in adequate detail how the
operational test will be met is a justifiable reason to deny a request for exemption. Your submission did not
provide clear evidence that your activities further an exempt purpose. Simply stating you are dedicated to
educating, inspiring and empowering Christians does not provide sufficient evidence of operating exclusively
for exempt purposes. When asked for clarity and more detail, your response did not demonstrate how your
activities were operated exclusively for exempt purposes or operated in an exempt manner. You provided no
details on any prayer meetings, events and/or outreaches. You did not submit any examples of materials and/or
resources you would use to promote and advance the word of God on spiritual and moral issues. There was no
explanation of how or why you would form other local chapters or how doing so would further an exempt
purpose. Further, you provided no additional details on your planned political campaign intervention or attempts
to influence legislation. Thus, you fail the operational test as noted in Treas. Reg. Section 1.501(c)(3)-1(c)(1).

The organization seeking a tax exemption has the burden of establishing its right to a tax-exempt status [See
Universal Life Church, Inc.]. You have not met your burden of proof that you qualify for tax exemption you are
seeking.

## Conclusion

The indications that you will participate in political campaign intervention bars you from being recognized as
exempt under IRC Section 501(c)(3). Further, you do not meet the organizational or operational tests required
under Section 501(c)(3).

## If you agree

If you agree with our proposed adverse determination, you don't need to do anything. If we don't hear from
you within 30 days, we'll issue a final adverse determination letter. That letter will provide information on
your income tax filing requirements.

## If you don't agree

You have a right to protest if you don't agree with our proposed adverse determination. To do so, send us a
protest within 30 days of the date of this letter. You must include:

· Your name, address, employer identification number (EIN), and a daytime phone number

· A statement of the facts, law, and arguments supporting your position

· A statement indicating whether you are requesting an Appeals Office conference

· The signature of an officer, director, trustee, or other official who is authorized to sign for the
organization or your authorized representative

· The following declaration:

For an officer, director, trustee, or other official who is authorized to sign for the organization:
Under penalties of perjury, I declare that I have examined this request, or this modification to the
request, including accompanying documents, and to the best of my knowledge and belief, the request
or the modification contains all relevant facts relating to the request, and such facts are true, correct,
and complete.

Your representative (attorney, certified public accountant, or other individual enrolled to practice before the
IRS) must file a Form 2848, Power of Attorney and Declaration of Representative, with us if they haven't
already done so. You can find more information about representation in Publication 947, Practice Before the
IRS and Power of Attorney.

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We'll review your protest statement and decide if you gave us a basis to reconsider our determination. If so,
we'll continue to process your case considering the information you provided. If you haven't given us a basis
for reconsideration, we'll send your case to the Appeals Office and notify you. You can find more information
in Publication 892, How to Appeal an IRS Determination on Tax-Exempt Status.

If you don't file a protest within 30 days, you can't seek a declaratory judgment in court later because the
law requires that you use the IRC administrative process first (IRC Section 7428(b)(2)).

Where to send your protest
Send your protest, Form 2848, if applicable, and any supporting documents to the applicable address:

U.S. mail:

Street address for delivery service:

Internal Revenue Service

Internal Revenue Service

EO Determinations Quality Assurance

EO Determinations Quality Assurance

Mail Stop 6403

550 Main Street, Mail Stop 6403

PO Box 2508

Cincinnati, OH 45202

Cincinnati, OH 45201

You can also fax your protest and supporting documents to the fax number listed at the top of this letter. If you
fax your statement, please contact the person listed at the top of this letter to confirm that they received it.

You can get the forms and publications mentioned in this letter by visiting our website at www.irs.gov/forms-
pubs or by calling 800-TAX-FORM (800-829-3676). If you have questions, you can contact the person listed at
the top of this letter.

Contacting the Taxpayer Advocate Service

The Taxpayer Advocate Service (TAS) is an independent organization within the IRS that can help protect your
taxpayer rights. TAS can offer you help if your tax problem is causing a hardship, or if you've tried but haven't
been able to resolve your problem with the IRS. If you qualify for TAS assistance, which is always free, TAS
will do everything possible to help you. Visit www.taxpayeradvocate.irs.gov or call 877-777-4778.

Sincerely,

Stephen A. Martin
Director, Exempt Organizations
Rulings and Agreements

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