Does Anyone Really Think the Family Research Council Is a Church?

“The Church is not an automobile showroom – a place to put ourselves on display so that others can admire our spirituality, capacity, or prosperity. It is more like a service center, where vehicles in need of repair come for maintenance and rehabilitation.”  Dieter F. Uchtdorf

I bought her a little pillow when my first baby grew old enough. My husband asked me about it. I told him it was just like those children’s books that described things like “What is a zebra?” So, we began to call it “What is a pillow?” I was going through a box recently and found it, still remembering.

Last week I wrote Christian Entities Like Samaritan’s Purse Claim They Are Churches to Hide Salaries and Donors. What Else Are They Lying About? It looks like this situation is garnering some interest on the part of legislators.

First, what is a church?

I know it is the entire body of believers. For some, it is a group of believers gathering around an agreed-upon definition of shared beliefs that meets regularly for worship. I found this definition to be helpful.

The Church Local Versus the Church Universal

The local church is defined as a local assembly of believers or a congregation that meets together physically for worship, fellowship, teaching, prayer, and encouragement in the faith (Hebrews 10:25). At the local church level, we can live in relationship with other believers—we break bread together (Holy Communion), we pray for each other, teach and make disciples, strengthen, and encourage one another.

At the same time, all believers are members of the universal church. The universal church is made up of every single person who has exercised faith in Jesus Christ for salvation, including members of every local church body throughout the earth:

Due to a confusing definition of what constitutes a church in the IRS coding, a number of Christian organizations have declared themselves to be a church. It appears that some politicians are calling “Foul.” Julie  Roys posted Democrats Call On IRS To Review Family Research Council’s ‘Church’ Status.

House Democrats are asking the IRS to review the tax-exempt status of a prominent conservative advocacy group recently reclassified as a church, arguing the organization may be exploiting the designation to avoid scrutiny.

Forty Democratic lawmakers, led by U.S. Reps. Suzan DelBene of Washington state and Jared Huffman of California, outlined their concerns in a letter sent to the head of the IRS and the secretary of the Treasury on Monday, singling out the Family Research Council (FRC). According to a recent report from ProPublica, the FRC successfully applied to be reclassified as a “group of churches” in 2020.

Lawmakers say that while the FRC often appeals to faith and advocates for a “biblical worldview,” the status change “strains credulity” because the group operates primarily as “a political advocacy organization.”

Let’s look at the letter to see how these members of Congress/the IRS define a church.

The IRS list of attributes of a church, developed in conjunction with court decisions, includes the following:

  •   Distinct legal existence;
  •   Recognized creed and form of worship;
  •   Definite and distinct ecclesiastical government;
  •   Formal code of doctrine and discipline;
  •   Distinct religious history;
  •   Membership not associated with any other church or denomination;
  •   Organization of ordained ministers;
  •   Ordained ministers selected after completing prescribed courses of study;
  •   Literature of its own;
  •   Established places of worship;
  •   Regular congregations;
  •   Regular religious services;
  •   Sunday schools for the religious instruction of the young; and
  •   Schools for the preparation of its members.

There is a limitation in the law which governs the amount of political activity in the said church. The definition hinges on is “substantial part of activities devoted to political action.” The members of Congress who signed this letter believe that it is clear that the Family Research Council devotes a significant amount of time to politics.

All section 501(c)(3) organizations, including churches, “must not devote a substantial part of their activities to attempting to influence legislation, political activity, or public policy.”2 The FRC is primarily a political advocacy organization that is “committed to advancing faith, family, and freedom in public policy and the culture from a biblical worldview.”3 Recently, the FRC filed amicus briefs supporting the overturning of Roe v. Wade, advocated for legislation that would ban gender-affirming surgery, and sought religious exemptions to civil rights laws.4 FRC claiming to be a church strains credulity: they do not hold religious services, do not have a congregation or affiliated congregations, and do not possess many of the other attributes of churches listed by the IRS5. FRC is one example of an alarming pattern in the last decade – right- wing advocacy groups self-identifying as “churches” and applying for and receiving church status.

The following statement troubles me, not due to the actions of Congressional members but due to the perception that the FRC and other Christian organizations are ABUSING the tax code.

Given that the FRC is primarily an advocacy organization and not a church,6 we urge the IRS to swiftly review the tax-exempt status, and whether there are other political advocacy organizations that have obtained church status, but do not satisfy the IRS requirements for churches, integrated auxiliaries, and conventions or associations of churches. Further, we urge the IRS to improve the review process for organizations seeking church status to ensure that organizations that are not churches cannot abuse the tax code. Finally, we request the IRS determine whether existing guidance is sufficient to prevent abuse and what resources or Congressional actions are needed to ensure adequate implementation and enforcement moving forward.

What happens when the actions of some Christian organizations are seen as just more groups out to play games with the tax code?

Is it worth the sacrifice of integrity to save some money? Yes, I know that it is not “their” money they are saving but the donor’s money they are saving. Some groups who have done this are:

  • Samaritan’s Purse
  • Billy Graham Evangelistic Association
  • The Navigators
  • Willow Creek Association
  • The now-defunct Ravi Zacharias Internation Ministries

Guess what “churches” don’t need to report? That’s right, salaries.

Baptist News Global posted When is a ‘church’ not really a church? Only when defined by the IRS.

Through Form 990, any donor or interested person may easily learn about a nonprofit’s financial status and get an idea for how it spends its money. All Form 990s are available for public view on the IRS website and on the websites of other donor-focused sites such as GuideStar.

But that information is not required of churches. Thus, critics of Franklin Graham who believe he receives exorbitant compensation from Samaritan’s Purse and BGEV — reportedly more than $700,000 annually from Samaritan’s Purse alone — have zero access to documentation to prove their case.

It is one thing for a local church not to be required to report the $70,000 annual salary given its pastor. Still, quite another for a multimillion-dollar nonprofit to be able to shield from donors the $700,000 salary of its president.

Even SBC entities play this game. Did you know that the North American Mission Board’s salaries are hidden?

A small difference is that SBC entities are required by the denomination to file annual financial reports that are published online, while parachurch organizations like Samaritan’s Purse or Family Research Council have no such oversight and make very little financial information public. But the financial reports published by the SBC do not include all the same information required on an IRS Form 990 — specifically, compensation information for leaders.

Lately that has frustrated critics of the SBC’s North American Mission Board, who believe leaders of the Atlanta-based agency are living large on church offerings.

It’s not just the SBC agencies that get to shield such information by being classified as churches; all denominational entities in the U.S. are able to claim the same. It is the parachurch ministries that previously were left out because they can’t claim the cover of a denomination.

What is the  Johnson Amendment?

Whether a nonprofit is classified as a church or not has no bearing on the Johnson Amendment, an IRS regulation in the news lately.

This 1954 law says 501(c)(3) organizations — which includes churches and many other nonprofits — may not endorse political candidates or participate in partisan political campaigns, under threat of losing their nonprofit status. Being labeled a “church” does not take away scrutiny on this issue; in fact, it likely increases scrutiny.

Now, this is another subject entirely. We all know churches that routinely ignore this. Baptist News Global posted a funny account of the most unusual Greg Locke.

Greg Locke, pastor of Global Vision Church in Nashville, Tenn. Locke has made all manner of outlandish declarations, including denying the reality of COVID-19, saying there are witches in his church and he knows who they are, to declaring that he will not allow any Democrats to be members of his church and that no Democrat can be a Christian.

This statement was in violation of the Johnson Amendment, but Locke, as usual, responded in his typical fashion and dissolved his 501c3.

Locke beat the IRS to the punch, however. In a May 22 sermon, he announced: “I dissolved our stinking 501(c)(3) in this church, because the government ain’t gonna tell me what I can and what I can’t say. So IRS, we don’t need your stupid tax exempt status. You can put it in a bag and burn it in your front yard for all we care. I renounce 501(c)(3) communism in this church! So we’ll say what we want to, Skippy Lou. The IRS, the FBI and everybody we’ve been turned in to can eat my dirty socks on live TV. I’m sick of it!”

Do you think God cares if we fudge?

And so it goes. On my long drive, I’ll read your thoughts on “What is a church?”.


Does Anyone Really Think the Family Research Council Is a Church? — 27 Comments

  1. Psalm 51, of David (composed after Nathan confronted his notorious crimes in “the matter of Uriah and Bathsheba”) says that God desires “truth in the inward parts.”

    I’m inclined to think that this kind of (as it seems to me) chicanery does not qualify.

    Does God care? He certainly cared, per Nathan, about the disrepute brought on His Name because of the misdeeds of Israel’s anointed king. But maybe the connection between God’s Name and present-day christian culture-war advocacy groups is sufficiently tenuous that it’s not a problem. In David’s day, people expected God’s appointed king to obey God’s laws; when he didn’t, that reflected poorly on the deity that had appointed him. Maybe in our day public expectations related to the conduct of christian leaders is sufficiently low that serious further reputational damage is not likely.

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  2. Sorry — didn’t answer the question, “what is a church?”

    Here’s an open-ended suggestion (and perhaps overly broad; I’m leaning heavily on the epistle I John for this):

    A “church” is a group of people who periodically assemble together for the purpose of encouraging one another to live the life of the Age to Come within the horizon of the present age.

    By that definition, perhaps the FRC could squeeze in.

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  3. Do I think FRC is a church? Do they have a membership list complete with signed contracts by said members? If not, how does the FRC “pastor” know whose souls he is responsible to God for?

    How many members have they disciplined in the past year?

    You can’t be a church if you don’t have that membership list and routinely exercise church discipline.

    Mark Dever

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  4. Unfortunately, when Christian groups who know full well they are not churches play these games it makes Christians look bad in general. We aren’t supposed to look like the world. We are supposed to look like the One we follow. I can’t help but wonder, did the decision to claim themselves as a church come about after much fasting, prayer, searching the scriptures, and seeking after God? Or was it a group of men in a board room with their legal and tax advisors applying the wisdom of men? I don’t know, but I doubt it was the former.

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  5. I think when groups like the Family Research Council claim to be a “church” for the perceived financial (or other) benefits, they need to ask themselves how they’d feel about their opponents using the same tactics. If they have no problem with their opponents doing the same thing, well, at least they’re not hypocrites. But if they don’t like the idea when the tables are turned, they probably shouldn’t be doing it, either.

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  6. “Do you think God cares if we fudge?”

    Fudge: a chocolate candy treat that Grandma used to make for us over the Holidays. Yum!

    Looked up “fudge” beyond the yummy candy:
    -tell the truth

    Where God guides, He provides. Perhaps if God is neither guiding nor providing, a non-profit fudges under the lie of “church” where transparency is also not in practice.

    These posts are both informative and a warning to all well-intentioned supporters (volunteers, donors, fans). Thx, Dee.

    Contrast: Simon Sinek highly recommends honesty & truth, in business, but one would suppose that honesty & truth would be important at “Christian” non-profits, too.
    “Take the Risk of HONESTY – Honesty pays dividends of trust, which is good business.”
    2.11 minutes:

    Note: Simon Sinek has youtube videos where he is speaking at conferences connected with MacArthur, Hybels, etc. Little does Sinek know that though he is in no way an Evangelical, his standards of ethics far exceed any of these so-called Christian orgs that hire him as a speaker. They book him because Sinek is a best-selling author. But Sinek has succeeded with honesty and transparency, unlike these Evangelical orgs and individuals, apparently.

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  7. Ava Aaronson,

    One thing leads to another.

    After posting Simon Sinek’s statement & link re: honesty, up popped Pastor Carey Nieuwhof, former attorney and founder of Connexus Church, interviewing Sinek on his, Nieuwhof’s, podcast.

    Turns out Nieuwhof shows up in TWW comments with links where he supports pastors Pete Wilson and Perry Noble because of their pastor burn-out. Of course, Nieuwhof has solutions: conferences, summits, books for sale.

    As a matter of fact, interspersed with his blog/advice column are sales offers of all of the above. It appears Nieuwhof was a lawyer, then a pastor, now a consultant for church leadership with lots of stuff to sell, and solve our church leadership problems like pastor burn-out.

    As he interviews Simon Sinek, Nieuwhof oooohs and aaaahs over Sinek’s path to success in business – because Sinek is actually successful in his own right. Very successful. It’s his business – not labelled as a church, nor does he call himself a pastor or collect donations. Sinek is a wage earner who files his income and pays taxes like us. Nothing to hide, no misrepresentation. Sinek recommends honesty and seems to follow his rules.

    When will pastors realize that church is not a business enterprise and becoming a Christian is not self-help? Pastoring is not an industry of selling self-help via books, conferences, consultations, summits, etc.

    Church is a community of Jesus followers. All followers are gifted FREE by the Holy Spirit, including the gift (not grift) of pastoring, for the benefit of the Body of Christ. Romans 12, 1 Corinthians 12, Ephesians 4.

    Becoming a Christian is NOT self-help and all the self-help books in the world do not make one a follower of Christ. There is one book – the Bible, the Word of God – that helps in following Jesus, our relationship with God.

    Nowadays, the Bible is free online. There are printed Bibles offered free, and a person only needs one in their lifetime. Pretty simple deal. Not a growth industry.

    Capitalism + Christianity is not following Jesus. Nothing about Jesus ministry involved collections or sales campaigns. If the non-profits really want to be churches, then do it like Jesus and His disciples did: free. (The collections in Acts went to the poor.) If a disciple was given support, it wasn’t cash or shekels, it was room and board until they moved on to the next town. No private planes galivanting willy-nilly around the world. In our digital age of Zooming, ditching the pastor plane fad is a no-brainer.

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  8. All I can say is church has always been a racket.

    The Doctrine of Discovery for the RC church is a perfect example. Any lands populated by non-christians automatically belonged to the church.

    In fact vast tracts of our province became church property. They made a tidy profit as the city expanded.

    Praise be…

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  9. I think it’s high time that the Congress take a second look at what a ‘church’ is and what it is not.
    Just in terms of fairness alone, it’s not fair that little working people get sodomized (so to speak) all year by the tax man, and the big guys in the religion-bizz skate by with gunny sacks of moolah.
    The IRS list of attributes up-top would be a good place to start enforcement.

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  10. Hmmmmm. Seems that all of these organizations are evangelical in nature. All evangelical churches that I am aware of have baptisms.
    The FRC was founded in 1983. In it’s nearly 40 years, how many people has their “pastor” baptized into the fold? ……..just wondering……… Samaritan’s Purse??? Are theses churches congregational, or elder led? Fellowship potlucks? Bible study groups? Choir, or band? Children’s ministries? Y’all know the list goes on……..
    Is there even any hint that these organizations might be churches? I don’t think so.
    They’re just “Jesus-centered” political action, fundraising, money-for-free tax scam organizations.

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  11. Greg Locke, pastor of Global Vision Church in Nashville, Tenn. Locke has made all manner of outlandish declarations, including denying the reality of COVID-19, saying there are witches in his church and he knows who they are, to declaring that he will not allow any Democrats to be members of his church and that no Democrat can be a Christian.

    This statement was in violation of the Johnson Amendment, but Locke, as usual, responded in his typical fashion and dissolved his 501c3.

    I’m not sure this statement is evidence of a violation of the Johnson Amendment (though Locke has almost certainly done so at other times). Churches are allowed to discriminate on many grounds and some that are against voting at all might not allow members to belong to any political party. It is when it turns to positive action such are requiring or encouraging members to join a particular political party or to vote for (or against) a particular candidate that the violation takes place.

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  12. Answer: No.

    And I suspect that some of the “congregation” at the FRC “church” are members of churches where they have signed covenants.

    I hate this playing around with the tax law so that you can get the benefits of being tax exempt but don’t have to show what your finances are like like every other 501(c) secular or religious not a church non-profit. Form 990 is not perfect by any stretch of the imagination, but there can be some eye-popping info on there. Which is why the Family Research Council made itself a “church.”

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  13. Erp: Anything to hide where the money is going.

    I note “Carbon12: Cryptocurrency to fortify, and unite the church” has just been announced. Any guesses on how many ways this could go wrong?

    Actually, putting transactions on the blockchain makes them more visible, rather than less. Once you get hold of wallet names (which is easier than you think, there’s specialized software and people who specialize in doing just this), it’s possible to track currency flows. And then when you link up wallet names to real-life names, it’s possible to see where money came in and money went out.

    I would note that this Carbon12 “coin”, like so many other ****coins, is backed by nothing. Even fiat currency, e.g., the US dollar, is backed by the “full faith and credit of the United States,” which is worth a lot more than a “currency” created on some person’s hard drive. *None* of these coins have anything backing them and the biggest / “most valuable” of them, Bitcoin, uses up massive amounts of energy to “mine” coins. I just checked, and Bitcoin is no longer using the energy equivalent of Finland every year (83 terawatt hours) to mint coins. It’s now up to using the energy equivalent of Argentina (131.26 terawatt hours). That’s an ENORMOUS amount of energy being used every day for a coin that has absolutely nothing else backing it up.

    I could say a LOT more about this, but me ranting about cryptocurrency is not the purpose of this website. If you are interested in learning more, one of my friends from Scientology protesting days, David Gerard, has a couple of books about cryptocurrency and a website where he regularly tracks the various legal and financial shenanigans of crypto, coins, NFTs, Web3, etc. He’s no slouch; he testified before a UK parliament committee on crypto at the end of June. But if I could leave you with one thing, it would be this: don’t buy crypto or anything related to it. It’s a sucker’s bet.

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