Watchdog Group Supplements Request for IRS Investigation Into Church's Activities
Watchdog Group Supplements Request for IRS Investigation Into Church's Activities
- AuthorsSloan, Melanie
- Institutional AuthorsCitizens for Responsibility and Ethics in Washington
- Cross-Reference
- Code Sections
- Subject Area/Tax Topics
- Jurisdictions
- LanguageEnglish
- Tax Analysts Document NumberDoc 2007-3557
- Tax Analysts Electronic Citation2007 TNT 29-58
February 9, 2007
The Honorable Mark W. Everson
Commissioner
Internal Revenue Service
1111 Constitution Avenue, N.W.
Washington, D.C. 20004
Dear Commissioner Everson:
Citizens for Responsibility and Ethics in Washington ("CREW") respectfully submits this supplemental information regarding its February 8, 2007 complaint against Living Word Christian Center ("LWCC"), located in Brooklyn Park, Minnesota. CREW has learned additional information regarding the make and model of a plane currently owned by Senior Pastor James Hammond that may shed additional light on the nature of the airplane leaseback scheme discussed in our February 8, 2007 complaint.
As CREW explained, Mr. Hammond leased two planes to LWCC under a non-cancellable operating lease that required LWCC to cover operational expenses including maintenance, fuel and staff costs. Letter from Melanie Sloan, Executive Director, CREW to Mark W. Everson, Commissioner, Internal Revenue Service (February 8, 2007) ("LWCC Complaint") at 2. LWCC reported using the planes, "to transport the Senior Pastor and/or staff to national events and speaking engagements, and to transport guests, speakers, educators, and others to and from [LWCCJ's Main Campus in the Minneapolis/St. Paul area." Id. at 4.
CREW has learned that Mr. Hammond currently owns a 1995 Flugzeugbau EA-300L, a plane described by the manufacturer as, "[w]ithout a doubt . . . the premiere aerobatic, sport and professional aircraft on the market today." Extra Aircraft, EA-300L, http://www.extraaircraft.com/ea300L.asp (attached as Exhibit A). The EA-300L is a two-seat plane primarily used for acrobatics and stunt flying. See ExtraAircraft.com, Flugzeugbau EA-300L gallery (February 8, 2007) (attached as Exhibit B). Federal Aviation Administration ("FAA") records confirm Mr. Hammond's ownership of the plane. FAA Registry of James M. Hammond (February 8, 2007) (attached as Exhibit C). This may well be one of the two planes that Mr. Hammond owned and leased to LWCC. See LWCC Complaint at 4. Under that lease, LWCC paid for all fuel and maintenance costs. Id. There is no conceivable exempt purpose for a church to pay for the personal, recreational use of its pastor's stunt plane. If LWCC paid for the fuel and maintenance costs for Mr. Hammond's EA-300L, that would constitute additional evidence that the church violated tax law's private inurement prohibition. 26 C.F.R. § 1.501(c)(3)-1(c).
CREW believes that this merits an immediate investigation by the IRS. Thank you for your consideration of this important matter. Please contact me if I can provide additional information or be of further assistance.
Melanie Sloan
Executive Director
Citizens for Responsibility and
Ethics in Washington
Washington, D.C.
cc: IRS -- EO Classification, Dallas
- AuthorsSloan, Melanie
- Institutional AuthorsCitizens for Responsibility and Ethics in Washington
- Cross-Reference
- Code Sections
- Subject Area/Tax Topics
- Jurisdictions
- LanguageEnglish
- Tax Analysts Document NumberDoc 2007-3557
- Tax Analysts Electronic Citation2007 TNT 29-58