Freedom From Religion Reports Possible Campaigning by Church

November 6, 2018

Mary A. Epps
Internal Revenue Service
Exempt Organizations Examination Office
1100 Commerce St
MC 4910 DAL
Dallas TX 75242

Dear Ms. Epps:

I am writing on behalf of the Freedom From Religion Foundation (“FFRF”) to report potential illegal political campaigning that occurred at Grace of God Church in New Port Richey, Florida. FFRF is a nationwide nonprofit with more than 32,000 members which works to protect the constitutional separation of church and state and to educate the public on matters related to nontheism.

We were recently informed that on November 6, 2018, midterm election day, Grace of God Church on Rowan Road in New Port Richey posted a political sign on its property. Grace of God Church serves as a Pasco County polling location, and the sign was posted on church property 100 feet away from where ballots were cast. We understand the sign read, “DON'T VOTE FOR DEMOCRATS ON TUESDAY AND SING 'OH HOW I LOVE JESUS' ON SUNDAY,” followed by an exclamation point drawn out of a cross. The Pasco County Supervisor of Elections Brian Corley asked church pastor Al Carlisle to remove the sign from church property. Pastor Carlisle indicated he put it there but he refused to remove it.¹ The Church of God posted the sign on its Facebook page and in response to suggestions that it violated Section 501(c)(3) of the tax code, indicated it was willing to “risk losing our 501-3C and honor our sacred rights to free speech,” Please see the attached screen shots.

IRS regulations specify that 501(c)(3) organizations, which include churches and other religious organizations, are prohibited from “[p]articipating in or intervening in] . . . any political campaign on behalf of (or in opposition to) any candidate for public office,” Rev. Rul. 2007-41, 2007-25 I.R.B. (June 28, 2007),

By permitting signs opposing political candidates to be erected on its property, particularly on election day while serving as a polling location, the church appears to have inappropriately used its religious organization to participate in a political campaign. It violated IRS regulations, apparently with full knowledge and disregard of its obligations under the tax code, by expressing opposition to a group of candidates for political office. Given these partisan activities, Grace of God Church violated the 501(c)(3) tax-exempt rules, which prohibit electioneering. 

FFRF respectfully requests that the IRS commence an immediate investigation of Grace of God Church, The IRS should take appropriate action to remedy any violations of 501(c)(3) regulations.

Thank you for your time and attention to this matter,

Elizabeth Cavell
Associate Counsel
Freedom From Religion foundation
Madison, WI