Exhibit 415

26 U.S.C. § 7611 (restrictions on church tax inquiries and examinations; Church Audit Procedures Act)

Exhibit 415 · Statute

26 U.S.C. § 7611 (restrictions on church tax inquiries and examinations; Church Audit Procedures Act)

The Secretary may begin a church tax inquiry only if— (A) the reasonable belief requirements of paragraph (2), and (B) the notice requirements of paragraph (3), have been met.

Conditions for a church tax inquiry: a written reasonable belief by an appropriate high-level Treasury official (a)(2) and written notice stating the concerns (a)(3). Examination of church records only as necessary to determine tax liability, with 15 days notice and an offered conference (b). Completion within 2 years of the examination notice, or 90 days for an inquiry with no examination (c)(1). Revocation, deficiency notice or assessment requires written approval of regional counsel (d)(1). Section 7611(i) excludes criminal investigations and willful evasion. Text read at the Cornell LII copy.

Source: United States Congress (Internal Revenue Code; added by Pub. L. 98-369 § 1033, 18 July 1984)
Date: 1984; as in force 2026
Quoted from: 26 U.S.C. § 7611(a)(1)
Grade: Primary record
Document: https://www.law.cornell.edu/uscode/text/26/7611
Accessed: 2026-11-09
Cited by: Findings citing this exhibit

Cited by

Finding REL-4.2: Primary record The Church Audit Procedures Act of 1984 (26 U.S.C. § 7611) permits the IRS to begin a church tax inquiry only on a written reasonable belief held by an appropriate high-level Treasury official and written notice to the church, and requires written approval of regional counsel before a revocation, deficiency notice or assessment. Congress enacted it after a 1983 Senate hearing at which the chairman cited constitutional entanglement and the harm of extended examinations to small congregations.