So why does the ProPublica site cease reporting at 2015? The operation is still active and as cloyingly annoying as ever, going back decades, to well before the Michele Bachmann bullhorn displays during her tenure in DC, indeed before and during her Minnesota legislative days when she declared Dobson as a mentor.
I.e., the bundle of affairs known as "Focus on the Family" went dark by the multi-million dollar basket of operations shifting to the dark side of IRC Sect. 501(c)(3) status - declaring itself not a think tank or idea advocate, but instead, a "church."
A major lawfirm specializing in advising non-profit entities states online:
What is a church? According to materials released early 2018, the venerable Christian radio and publishing ministry Focus on the Family pressed that question with the IRS, successfully garnering official reclassification as a “church.” The IRS’s willingness to accede to Focus’ request, as reflected in recently released IRS documentation, may be surprising and certainly invites further evaluation of what constitutes a “church” for legal purposes.
Why and How to Define “Church”?
As a foundational matter, why does it matter whether a faith-based organization is a “church” for government purposes? Perhaps most significantly from the IRS perspective, “churches” (and other religious institutions like synagogues and mosques; collectively identified here as “churches”) qualify as Section 501(c)(3) public charities, but they are not required to file annual IRS Form 990s like their tax-exempt counterparts. Correspondingly, while they may file IRS applications for tax-exempt recognition (or in this case, an application for reclassification), churches are deemed automatically tax-exempt per Section 508 of the Internal Revenue Code. In addition, churches may enjoy broader religious liberty protections, such as exemption from the Affordable Care Act’s mandate on insurance coverage for contraception, employment-related religious exemptions, and an easier path to property and sales tax exemptions.
But how does the government – in particular, the IRS – define a “church”? Webster’s dictionary defines a church as “a building for public…worship; a body or organization of religious believers; a denomination; a congregation.” Others may say that a church is a church—you know it when you see one. Just look for the steeple, people bowed in worship, prayers, hymns, and clergy in robes. But is a church really that easy to identify? For some religious institutions, perhaps; but for a historic radio ministry dedicated to “promoting biblical truths worldwide,” the line between church and not is much blurrier than one might think. Yet the IRS agreed to call a radio ministry a church—why?
Focusing on Focus on the Family’s “Church” Qualification
Although Focus on the Family had filed IRS Form 990s for many years since its 1997 incorporation, it sought reclassification as a “church” in mid-2016 through a detailed IRS Form 8940 “Request for Miscellaneous Determination” that included the requisite Schedule A factors. The organization answered “Yes” to all but four questions, which concerned ministry ordination, denominational affiliation, and church charters. The IRS ultimately agreed, issued its reclassification letter for “church” status under Section 501(c)(3) of the Code.
Focus on the Family’s materials were extensive, detailing how and why it fit the IRS definition of “church,” and more specifically thirteen of the seventeen IRS factors. To do so, Focus on the Family emphasized its heavily religious nature, notwithstanding the absence of regular Sunday meetings and other trappings that one might expect for a traditional church.
For starters, and as with all churches, Focus on the Family set forth its articulated religious purpose, a Statement of Faith, “Six Pillars” of ministry based directly on Biblical principles, and membership qualities. With respect to membership, perhaps one of the more challenging elements here, the organization shared that its “membership” is comprised of its 600 employees and their families. While ordinarily it would be expected that “members” not be associated with other churches, Focus on the Family explained that it allows for multiple church membership based on its belief that the Holy Scriptures teaches cooperation between churches.
On a related note, Focus on the Family further shared that, consistent with its Christian doctrine, work is worship. At Focus on the Family, the work is to teach and equip the local church, as is common among all churches. Focus on the Family’s other forms of worship includes all-staff prayer meeting each Monday, small group gatherings each day, and monthly all-staff chapel meetings, including average attendance of approximately 750 at such monthly chapel services. The organization’s sacerdotal functions include a “Maundy Thursday” service and a commemoration of the Last Supper during Easter season, again through its members/employees as expressions of worship.
Focus on the Family has religious leadership, ecclesiastical government, and accompanying religious policies too. The Board of Directors function as an Elder Board, including the CEO/elder. The organization is elder-led, with no ordination or licensing needed based on elder model of leadership. There is also an Executive Cabinet made up of deacons and deaconesses, including the COO. The organization follows a “Formal Code of Doctrine and Discipline” based on Biblical principles like Matthew 18 (for conflict resolution), and other religious policies.
Significantly, Focus on the Family also has its own religious literature. It has published innumerable materials, all distinctly Christian, on faith, Christian worldview, Christian heritage, marriage, parenting, life challenges, social issues, and the sanctity of life.
Yeah. Sure. Not a propaganda outlet designed to solicit and receive millions of dollars every month, with hundreds on its payroll. From who, non-congregants? Likely, since the employees, those drawing a paycheck for Jesus, are reported above, to make up the "congregation."
RightwingWatch, (cited earlier next to the Darth Vader image), notes:
Focus on the Family declaring itself to be a church is puzzling. While the Colorado Springs-based organization has somewhat softened its image since it was led by the firebrand Dobson, it remains active in political debates and advocacy (even in a nominally nonpartisan way). A “social issues” section on the group’s website currently features information on a supposed threat to bathroom safety posed by transgender people thanks to LGBTQ activists fighting in politics, churches and popular culture, and contains an update on “cultural issues in the courts.” In June, Focus invited Vice President Mike Pence to speak at an event celebrating its 40th anniversary, where he promised the group it had an “unwavering ally” in President Trump.
Gail Harmon, an attorney who has advised nonprofits on tax law for more than 30 years, said that she had never before seen a nonprofit organization declare itself a church. “I just found it shocking,” she said.
“There’s nothing about them that meets the traditional definition of what a church is,” she said. “They don’t have a congregation, they don’t have the rites of various parts of a person’s life. There’s a whole system for what a church is.”
The IRS lists a number of factors that it considers in determining whether an organization is a church, including whether it has a “definite and distinct ecclesiastical government,” “established places of worship” and “regular religious services,” but notes that an organization “need not have all of the characteristics” listed in order to be considered a church.
Samuel Brunson, a tax law expert at the Loyola University Chicago School of Law, said that it is difficult to create clear rules on what counts as a church for taxation purposes without running afoul of the First Amendment. “Because of the First Amendment, Congress and the IRS are hesitant to create bright-line rules for fear of creating unconstitutional rules, which means that everything is fairly murky in the area,” he said.
[links omitted] Readers are strongly advised to follow both links, for a fuller view of this so-called "church." It is all an eye-opener.
What it all shows is: You pay piety, piety pays its insiders, your contribution is duly welcome. And they don't need to buy and burn incense.
IRS non-transparency? Is there cause for "church" status having been sought besides dodging the sunshine? Your guess is as good as mine. Given how Hobby Lobby shook out, legal exemption from having to provide employees contraception is not a special "church" thing.
Cozy for a "church?" One like Dobson's empire? Not having to render to Ceasar what is Caesar's cuts true either way, so money-wise it's a wash. But not having to make the cash flows or directorship and management compensation subject to public scrutiny, that is unique to a "church."
How then might you circumstantially infer motive?
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Those interested in Church-State topics might look here.