Chapter 5

Ministry as Business

Abstract

On 5 November 2007 the ranking member of the Senate Committee on Finance, Senator Charles Grassley, wrote to six media-based ministries and asked for financial and governance information. Two ministries answered all questions, and four answered in part or not at all. The committee's staff issued no subpoenas, and the January 2011 materials are a staff memorandum to Grassley, not a report adopted by the committee. The memorandum lists issues for consideration, and Grassley asked an evangelical accreditor to address them without legislation. The only court order found against a televised ministry in this record is a 2021 Missouri consent judgment on a silver product, in which the defendants deny wrongdoing. The Senate inquiry and that action concern Protestant media ministries only, and this chapter draws no conclusion about any faith or denomination. Organizations coded as religious in the federal Paycheck Protection Program (PPP) data received 122,665 loans totaling $9.31 billion, under a program that Congress enacted unanimously in the Senate and that two administrations ran. The PPP data covers every tradition and does not record denomination. No regulator order that applies across traditions was found.

5.1 The letters of November 2007

Finding REL-5.1Primary record

On 5 November 2007 Senator Charles Grassley, ranking member of the Senate Committee on Finance, wrote to six media-based ministries: those of Kenneth and Gloria Copeland, Creflo and Taffi Dollar, Benny Hinn, Eddie Long, Joyce and David Meyer, and Randy and Paula White. The letter to Hinn asks for audited financial statements, compensation, housing, vehicles, aircraft and related-entity information by 6 December 2007.

The Senate Finance Committee's press release of 6 November 2007 names the six recipients and the organizations that each led. Chairman of the committee at the time was Senator Max Baucus. Grassley, who had chaired the committee from 2003 to 2007, was ranking member. The inquiry opened as a request from the ranking member, and Baucus co-signed only the follow-up letters of 11 March 2008.

Evidence: Exhibit 438, Exhibit 439

§5.1.1

The six recipients were Randy and Paula White (Without Walls International Church, Tampa, Florida), Benny Hinn (World Healing Center Church, Grapevine, Texas), David and Joyce Meyer (Joyce Meyer Ministries, Fenton, Missouri), Kenneth and Gloria Copeland (Kenneth Copeland Ministries, Newark, Texas), Eddie Long (New Birth Missionary Baptist Church, Lithonia, Georgia) and Creflo and Taffi Dollar (World Changers Church International, College Park, Georgia). The committee called them media-based ministries, and all six are Protestant.

§5.1.2

The release gave the reason for the inquiry in Grassley's words: "The allegations involve governing boards that aren't independent and allow generous salaries and housing allowances and amenities such as private jets and Rolls Royces. I don't want to conclude that there's a problem, but I have an obligation to donors and the taxpayers to find out more." The committee's memorandum of 6 December 2007 stated its standard: "For the focus of this inquiry, ministries are the same as any other non-profit organization. It's a question of abiding by tax laws just like any tax-exempt group."

§5.1.3

The committee's July 2008 memorandum states that the selection rested on information from constituents, whistleblowers, other insiders and news reports. It states that the doctrine of the churches "was not part of his inquiry in any way."

§5.1.4

The Hinn letter asks for audited financial statements for 2004 to 2006, the names of board and compensation-committee members, compensation, housing, vehicles, aircraft and related entities, by 6 December 2007. The committee's March 2008 release states that the request contained 28 questions.

Exhibit 438 · Press release

Grassley Seeks Information from Six Media-based Ministries

The allegations involve governing boards that aren't independent and allow generous salaries and housing allowances and amenities such as private jets and Rolls Royces. I don't want to conclude that there's a problem, but I have an obligation to donors and the taxpayers to find out more.

Names the six ministries written to on 5 Nov 2007. Grassley was ranking member; Baucus was chairman.

Source: U.S. Senate Committee on Finance (ranking member Grassley)
Date: 6 November 2007
Quoted from: para. 2
Grade: Primary record
Document: https://webarchive.library.unt.edu/eot2008/20090103105108id_/http://finance.senate.gov/press/Gpress/2007/prg110607.pdf
Accessed: 2026-11-09
Cited by: Findings citing this exhibit
Note: The URL is an archived copy (Wayback Machine or UNT web archive); the issuer's original address is no longer the working copy.

Exhibit 439 · Congressional letter

Letter, Grassley to Benny Hinn (representative of the six 5 Nov 2007 letters)

Please provide the requested information on searchable disks or electronically by December 6, 2007.

Letter to Benny Hinn, one of six sent on 5 November 2007. It requests audited financial statements for 2004 to 2006, board and compensation-committee names, compensation, housing, vehicles, aircraft and related entities by 6 December 2007.

Source: U.S. Senate Committee on Finance
Date: 5 November 2007
Quoted from: Letter of 5 November 2007, p. 1 (scanned PDF read by OCR)
Grade: Primary record
Document: https://www.finance.senate.gov/imo/media/doc/prg110607b.pdf
Accessed: 2026-11-09
Cited by: Findings citing this exhibit

5.2 What each ministry answered

Finding REL-5.2Primary record

In the Senate Finance Committee's July 2008 account, Meyer and Hinn answered all questions, White answered two of the question groups, Copeland answered part of them and none on compensation, Long's reply was "not responsive," and Dollar declined to provide any of the requested information.

The committee published its own account of each response. Its 7 July 2008 memorandum says Meyer gave extensive answers to all questions and that staff found them substantively informative. It says Hinn gave extensive answers to all questions in a series of submissions. The 6 January 2011 release repeats that two ministries responded fully and that four provided no information or incomplete information.

Evidence: Exhibit 442, Exhibit 440, Exhibit 441, Exhibit 443

Responses to the 5 November 2007 letters, as the committee described them on 7 July 2008
Ministry	Committee's description
Meyer	Extensive answers to all questions; responses found in good faith and substantively informative.
Hinn	Extensive answers to all questions in a series of submissions.
White	Responses only to the general and the real and personal assets questions; submissions deemed incomplete.
Copeland	Partial responses to most questions and none to the compensation questions; staff deemed the submission "not responsive."
Long	General information, articles of incorporation and bylaws (which the committee had not requested); staff deemed the submission "not responsive."
Dollar	Declined to provide any of the requested information.

§5.2.1

The 6 December 2007 memorandum shows the early positions. Copeland's attorneys delivered a package that day. Dollar's ministry sent Grassley and Baucus a letter stating that it did not intend to provide information voluntarily. The memorandum says the Meyer package arrived on 4 December and that Long's ministry had publicly said it would cooperate but had sent nothing. The 31 March 2008 memorandum records that Hinn had answered five of the 28 questions and that Baucus and Grassley wrote to Hinn, Copeland, Dollar and Long on 11 March 2008.

§5.2.2

The March 2008 letter states: "While the inquiry is not part of an enforcement action, which would properly belong to the IRS, it is within the jurisdiction of the Committee to make these inquiries." It adds that the committee consulted the Senate Legal Counsel to keep the request within its authority and within the First Amendment.

The official position

Copeland's 6 December 2007 submission, as the committee's staff quotes it, states: "Based on constitutionally and statutorily based privacy and confidentiality concerns, the Church respectfully declines to provide the detailed accounting requested." The submission points to the IRS church tax inquiry procedure in section 7611 and to a request by the committee to the IRS under section 6103(f).

Hinn's ministry wrote on 9 September 2008 that it cooperated and made reforms, and that the review had made it more accountable. Meyer's ministry wrote on 10 December 2008 and listed governance steps, among them audits since 1995, an independent compensation committee since 2005 and a majority-independent board.

Counsel for Dollar raised First Amendment concerns and a concern that the inquiry targeted a religious movement, as Grassley's reply of 2 July 2008 characterizes them. In that reply, Grassley wrote that he did not know when he wrote to the six churches which of them belonged to that movement.

What the record shows

The committee's staff described Copeland's submission as not responsive. The staff described Hinn's and Meyer's answers as complete, and in the January 2011 memo it called the reforms by Hinn and Meyer "extensive" and "to be commended." The release states that Meyer joined the accreditor ECFA in March 2009.

The committee did not adjudicate any contested claim. The inquiry, in Grassley's words, "is not part of an enforcement action."

§5.2.3

The staff overviews released in January 2011 contain statements from public sources and third-party informants about named living people. The ministries did not confirm them and the committee did not adjudicate them. None is reported here.

Exhibit 440 · Press memorandum

Memorandum: Ministries' response to Nov. 5 inquiry

For the focus of this inquiry, ministries are the same as any other non-profit organization. It's a question of abiding by tax laws just like any tax-exempt group.

Status of each ministry at the 6 Dec 2007 deadline.

Source: U.S. Senate Committee on Finance (ranking member Grassley)
Date: 6 December 2007
Quoted from: para. 2
Grade: Primary record
Document: https://www.finance.senate.gov/imo/media/doc/prg120607b1.pdf
Accessed: 2026-11-09
Cited by: Findings citing this exhibit

Exhibit 441 · Press memorandum and letters

Memorandum and release: Ministry responses; Baucus-Grassley follow-up letters of 11 March 2008

While the inquiry is not part of an enforcement action, which would properly belong to the IRS, it is within the jurisdiction of the Committee to make these inquiries.

Chairman Baucus and Ranking Member Grassley wrote to four ministries; Hinn had answered five of 28 questions.

Source: U.S. Senate Committee on Finance
Date: 31 March 2008
Quoted from: 11 Mar 2008 letter, para. 3
Grade: Primary record
Document: https://webarchive.library.unt.edu/eot2008/20090102235502id_/http://finance.senate.gov/press/Gpress/2008/prg033108a.pdf
Accessed: 2026-11-09
Cited by: Findings citing this exhibit
Note: The URL is an archived copy (Wayback Machine or UNT web archive); the issuer's original address is no longer the working copy.

Exhibit 442 · Press memorandum

Memorandum: Ministry responses, with Background Questions and Answers

The doctrine of the churches was not part of his inquiry in any way.

Committee's own characterization of each ministry's response; Q&A on church tax rules and why Congress, not the IRS, was asking.

Source: U.S. Senate Committee on Finance
Date: 7 July 2008
Quoted from: Background Q&A, 'Doesn't the investigation raise constitutional issues'
Grade: Primary record
Document: https://webarchive.library.unt.edu/eot2008/20090102235502id_/http://finance.senate.gov/press/Gpress/2008/prg070708.pdf
Accessed: 2026-11-09
Cited by: Findings citing this exhibit
Note: The URL is an archived copy (Wayback Machine or UNT web archive); the issuer's original address is no longer the working copy.

Exhibit 447 · Staff review

Minority Staff Review of Eagle Mountain International Church d/b/a Kenneth Copeland Ministries

Based on constitutionally and statutorily based privacy and confidentiality concerns, the Church respectfully declines to provide the detailed accounting requested.

Quotes the ministry's 6 Dec 2007 reply declining the detailed accounting and pointing to IRS church tax inquiry procedure. Staff-derived facts rest on public records and unnamed informants.

Source: U.S. Senate Committee on Finance, minority staff (Simmons)
Date: 5 January 2011
Quoted from: p. 1
Grade: Primary record
Document: https://www.finance.senate.gov/imo/media/doc/EMIC%20Copeland%2001-5-11.pdf
Accessed: 2026-11-09
Cited by: Findings citing this exhibit

Exhibit 448 · Ministry letter

Letter, Benny Hinn Ministries to Senator Grassley

I believe you and your dedicated staff will confirm that, nearly 5,000 pages of production later, we have been thorough and comprehensive in our submissions.

Ministry's own account of cooperation and reforms.

Source: Benny Hinn Ministries
Date: 9 September 2008
Quoted from: Benny Hinn letter to Sen. Grassley, 9 Sep 2008, p. 1
Grade: Primary record
Document: https://web.archive.org/web/20120403034321/http://finance.senate.gov/newsroom/ranking/download/?id=8e055073-52f2-4c1f-8290-b4fc063b0f8a
Accessed: 2026-11-09
Cited by: Findings citing this exhibit
Note: The URL is an archived copy (Wayback Machine or UNT web archive); the issuer's original address is no longer the working copy.

Exhibit 449 · Ministry letter

Letter, Joyce Meyer Ministries to Senator Grassley

Voluntary financial audits have been performed by independent public accounting firms since 1995.

Lists governance steps (audits since 1995, independent compensation committee since 2005, majority-independent board).

Source: Joyce Meyer Ministries
Date: 10 December 2008
Quoted from: Joyce Meyer Ministries letter to Sen. Grassley, 10 Dec 2008, p. 1, item 1
Grade: Primary record
Document: https://web.archive.org/web/20120403034110/http://finance.senate.gov/newsroom/ranking/download/?id=25a6a53a-789c-4467-a2b9-c847a853a3be
Accessed: 2026-11-09
Cited by: Findings citing this exhibit
Note: The URL is an archived copy (Wayback Machine or UNT web archive); the issuer's original address is no longer the working copy.

Exhibit 450 · Correspondence

Letter, Caplin & Drysdale (counsel for World Changers Church International) to Finance Committee staff; Grassley reply 2 July 2008

Finally, you noted that it is Senate Finance Committee’s position that the investigation does not implicate the First Amendment rights of the members of World Changers Church International.

Letter of 5 June 2008 from Marcus S. Owens (Caplin & Drysdale) to Theresa Pattara, recording counsel's account of the staff call, including the Committee's stated position on First Amendment concerns. The same packet holds Grassley's 2 July 2008 reply to Creflo and Taffi Dollar; its section 'First Amendment Concerns' begins 'There is no question in my mind about the strength of the First Amendment protections for religious liberty' (p. 3). Counsel's November 2007 and March 2008 letters are described in the packet and are not in it.

Source: Caplin & Drysdale / U.S. Senate Committee on Finance
Date: 5 June 2008; 2 July 2008
Quoted from: Marcus S. Owens (Caplin & Drysdale) to Theresa Pattara, 5 Jun 2008, p. 1
Grade: Primary record
Document: https://web.archive.org/web/20120403034356/http://finance.senate.gov/newsroom/ranking/download/?id=7cc41cb9-7be6-4a42-ae58-c432a754d347
Accessed: 2026-11-09
Cited by: Findings citing this exhibit
Note: Scanned 12-page PDF. The URL is an archived copy; the issuer's original address is no longer the working copy.

5.3 Subpoenas that were not issued

Finding REL-5.3Primary record

The committee's staff did not issue subpoenas to the ministries or to informants. The staff memo of 6 January 2011 gives three reasons: subpoenas to informants would be counterproductive, committee rules require the chairman's participation, and the 2009 health-reform legislation left no time or resources.

The memo of 6 January 2011 states: "we believed that issuing subpoenas to informants would be counterproductive." It states that committee rules "require the participation of the Chairman." It states that health reform legislation, which began in the winter of 2009, "ensured that we would not have the time or resources to issue and enforce the subpoenas."

Evidence: Exhibit 444

§5.3.1

The memo concludes that, as a result, "staff also decided against issuing subpoenas to the churches." The memo states that its findings on the four non-cooperating ministries rest on public sources and third-party informants.

§5.3.2

The July 2008 memorandum said of Copeland that staff deemed the submission not responsive since Kenneth Copeland had declared publicly that he would not respond even if a subpoena issued. The same memorandum states that the inquiry was not an enforcement action and that Grassley supported voluntary, independent accreditation programs, among them ECFA.

§5.3.3

The release of 6 January 2011 states that Grassley's tenure as ranking member was ending because of Republican term limits.

Exhibit 444 · Staff memorandum

Memorandum to Senator Grassley: Review of Media-Based Ministries (61 pp.)

The Committee's consideration of health reform legislation, which began in the winter of 2009, ensured that we would not have the time or resources to issue and enforce the subpoenas. As a result, staff also decided against issuing subpoenas to the churches.

Staff review; why no subpoenas issued; issues for consideration (advisory committee, parsonage, filing, 4958, love offerings, electioneering). Not a committee-adopted report.

Source: U.S. Senate Committee on Finance, minority staff (Pattara and Barnett)
Date: 6 January 2011
Quoted from: p. 2
Grade: Primary record
Document: https://www.finance.senate.gov/imo/media/doc/SFC%20Staff%20Memo%20to%20Grassley%20re%20Ministries%2001-06-11%20FINAL.pdf
Accessed: 2026-11-09
Cited by: Findings citing this exhibit
Note: A minority-staff memorandum to Senator Grassley, not a report adopted by the committee.

5.4 The January 2011 staff memorandum

Finding REL-5.4Primary record

The materials released on 6 January 2011 are a minority-staff memorandum to Senator Grassley, not a report adopted by the committee. The memo frames issues for consideration and contains no bill text, and on 5 January 2011 Grassley asked the Evangelical Council for Financial Accountability whether the issues can be addressed without legislation.

The memo is 61 pages, written by minority staff Theresa Pattara and Sean Barnett, and titled "Review of Media-Based Ministries." The release of 6 January 2011 describes it as a staff review of six ministries and reports on other churches and religious organizations referred to the committee. Grassley's letter to ECFA states that he believes that "legislation should be the last resort."

Evidence: Exhibit 444, Exhibit 445, Exhibit 446, Exhibit 443

§5.4.1

The memo recommends that the IRS sponsor an advisory committee of representatives of churches and religious organizations. It frames the other items as "issues for consideration": the parsonage allowance, IRS filing requirements, church tax inquiries, excess-benefit rules, gifts received through charitable organizations ("love offerings") and electioneering. Appendix D lists governance and self-dealing issues for all organizations exempt under section 501(c)(3).

§5.4.2

The memo's recommendation against requiring every church to file Form 990, and the reasons it gives, are in section 4.7.

§5.4.3

Grassley's release states the committee's aim: "The challenge is to encourage good governance and best practices and so preserve confidence in the tax-exempt sector without imposing regulations that inhibit religious freedom or are functionally ineffective." The memo states that most churches operate with policies that make them accountable to their members, and that "it is the small minority that don't" that present tax policy issues.

§5.4.4

Grassley's letter of 5 January 2011 asks ECFA to consider the staff's issues and to lead a discussion of whether they can be addressed "without legislation." The memo contains no bill text.

§5.4.5

The details of exemption, filing and the parsonage allowance belong to Chapter 4. Section 4958 of the Internal Revenue Code taxes an excess benefit transaction at 25 percent of the excess benefit, with a further tax of 200 percent if it is not corrected.

Exhibit 443 · Press release

Grassley Releases Review of Tax Issues Raised by Media-based Ministries

The challenge is to encourage good governance and best practices and so preserve confidence in the tax-exempt sector without imposing regulations that inhibit religious freedom or are functionally ineffective.

Releases staff review; two ministries fully responded, four did not; refers issues to ECFA.

Source: U.S. Senate Committee on Finance (ranking member Grassley)
Date: 6 January 2011
Quoted from: para. 9
Grade: Primary record
Document: https://www.finance.senate.gov/ranking-members-news/grassley-releases-review-of-tax-issues-raised-by-media-based-ministries
Accessed: 2026-11-09
Cited by: Findings citing this exhibit

Exhibit 446 · Congressional letter

Letter, Grassley to Dan Busby, ECFA

I stated then that I believe that legislation should be the last resort.

Asks ECFA to address the staff's issues and whether they can be handled without legislation. Image checked by eye.

Source: U.S. Senate Committee on Finance
Date: 5 January 2011
Quoted from: para. 4
Grade: Primary record
Document: https://web.archive.org/web/2011/http://finance.senate.gov/newsroom/ranking/download/?id=5c0f3911-8eab-4dbe-b780-888ee451af0b
Accessed: 2026-11-09
Cited by: Findings citing this exhibit
Note: The URL is an archived copy (Wayback Machine or UNT web archive); the issuer's original address is no longer the working copy.

Exhibit 445 · Staff memorandum

Staff memo, Appendix C item 3 (IRS filing requirements)

we do not recommend completely eliminating the church exception to the filing requirements, i.e., we do not recommend requiring every church to file a Form 990.

Staff declined to recommend that every church file a Form 990.

Source: U.S. Senate Committee on Finance, minority staff
Date: 6 January 2011
Quoted from: p. 32
Grade: Primary record
Document: https://www.finance.senate.gov/imo/media/doc/SFC%20Staff%20Memo%20to%20Grassley%20re%20Ministries%2001-06-11%20FINAL.pdf
Accessed: 2026-11-09
Cited by: Findings citing this exhibit

5.5 Related entities and taxes

Finding REL-5.5Primary record

The staff memo states that four of the six churches refused to provide tax information, so staff could not determine whether and to what extent they report and pay taxes on income earned in related entities, including private airports and aircraft leasing companies.

The July 2008 memorandum states that preliminary staff research found almost 100 entities related to the six churches and the ministers. The January 2011 memo states that the number and types of entities, including private airports and aircraft leasing companies, raise concerns about use of tax-exempt status to avoid taxation.

Evidence: Exhibit 444, Exhibit 442

§5.5.1

The same memo states the limit on that concern: "given the four churches' refusal to provide tax information, we are unable to determine whether and the extent to which they are reporting and paying taxes on income earned in those entities." The memo records no finding that any entity owed tax.

§5.5.2

The four churches that did not provide the information are the four that the committee classed as nonresponsive or incomplete. The staff overviews' descriptions of the entities rest on informants, and the entities are not named here.

Exhibit 444 · Staff memorandum

Memorandum to Senator Grassley: Review of Media-Based Ministries (61 pp.)

The Committee's consideration of health reform legislation, which began in the winter of 2009, ensured that we would not have the time or resources to issue and enforce the subpoenas. As a result, staff also decided against issuing subpoenas to the churches.

Staff review; why no subpoenas issued; issues for consideration (advisory committee, parsonage, filing, 4958, love offerings, electioneering). Not a committee-adopted report.

Source: U.S. Senate Committee on Finance, minority staff (Pattara and Barnett)
Date: 6 January 2011
Quoted from: p. 2
Grade: Primary record
Document: https://www.finance.senate.gov/imo/media/doc/SFC%20Staff%20Memo%20to%20Grassley%20re%20Ministries%2001-06-11%20FINAL.pdf
Accessed: 2026-11-09
Cited by: Findings citing this exhibit
Note: A minority-staff memorandum to Senator Grassley, not a report adopted by the committee.

5.6 Constitutional limits and the accreditor

§5.6.1

Section 7611, which limits IRS church tax inquiries, and Walz v. Tax Commission (1970), which upheld the property-tax exemption for houses of worship, are described in section 4.2.

§5.6.2

In Gaylor v. Mnuchin, 919 F.3d 420 (7th Cir. 2019), the Seventh Circuit reversed a district court and held that 26 U.S.C. § 107(2), the clergy housing allowance, is constitutional. It described the provision as within the "play in the joints."

§5.6.3

ECFA's board chair wrote to Grassley on 21 April 2009 to oppose a requirement that churches file Form 990 or 990-N with the IRS. The letter describes annual filing as intrusion into church administration, including compensation practices.

§5.6.4

ECFA is a voluntary accreditor. Its standards, described in section 4.9, limit membership to evangelical Christian organizations. The staff memo noted that ECFA's Christian-centered approach may deter non-Christian churches from seeking accreditation, so the self-regulatory route covers organizations of that tradition.

§5.6.5

In December 2012 an ECFA commission of religious leaders reported to Grassley. Its chairman's message states that Grassley "specifically asked ECFA to seek solutions that rely on self-regulation and not on new burdensome legislation." The report acknowledges that "noncompliant outliers have little interest in self-regulation." No cited document ties ECFA's fees or standards to the outcome of any inquiry.

Exhibit 456 · Statute

26 U.S.C. 7611 (Church tax inquiries and examinations)

if an appropriate high-level Treasury official reasonably believes (on the basis of facts and circumstances recorded in writing)

Church Audit Procedures Act: written reasonable-belief and notice requirements before an IRS church inquiry.

Source: U.S. Code
Date: current
Quoted from: (a)(2)
Grade: Primary record
Document: https://www.law.cornell.edu/uscode/text/26/7611
Accessed: 2026-11-09
Cited by: Findings citing this exhibit

Exhibit 455 · Statute

26 U.S.C. 4958 (Excess benefit transactions)

there is hereby imposed on each excess benefit transaction a tax equal to 25 percent of the excess benefit.

25 percent tax on disqualified person, 10 percent on managers, 200 percent if uncorrected.

Source: U.S. Code
Date: current
Quoted from: (a)(1)
Grade: Primary record
Document: https://www.law.cornell.edu/uscode/text/26/4958
Accessed: 2026-11-09
Cited by: Findings citing this exhibit

Exhibit 454 · Statute

26 U.S.C. 107 (Rental value of parsonages)

In the case of a minister of the gospel, gross income does not include—

Excludes from a minister's gross income the rental value of a furnished home or a rental allowance capped at fair rental value.

Source: U.S. Code
Date: current
Quoted from: opening clause
Grade: Primary record
Document: https://www.law.cornell.edu/uscode/text/26/107
Accessed: 2026-11-09
Cited by: Findings citing this exhibit

Exhibit 469 · Court opinion

Walz v. Tax Commission, 397 U.S. 664

Elimination of exemption would tend to expand the involvement of government by giving rise to tax valuation of church property, tax liens, tax foreclosures, and the direct confrontations and conflicts that follow in the train of those legal processes.

Upholds property-tax exemption for houses of worship; 'benevolent neutrality'; elimination would increase entanglement.

Source: U.S. Supreme Court
Date: 4 May 1970
Quoted from: Part IV; pin cite to verify
Grade: Primary record
Document: https://www.law.cornell.edu/supremecourt/text/397/664
Accessed: 2026-11-09
Cited by: Findings citing this exhibit

Exhibit 457 · Court opinion

Gaylor v. Mnuchin, 919 F.3d 420 (7th Cir. 2019)

We conclude § 107(2) is constitutional. The judgment of the district court is REVERSED.

Reversed the district court and held section 107(2) constitutional under the Establishment Clause.

Source: U.S. Court of Appeals for the Seventh Circuit
Date: 15 March 2019
Quoted from: p. 29
Grade: Primary record
Document: https://www.govinfo.gov/content/pkg/USCOURTS-ca7-18-01277/pdf/USCOURTS-ca7-18-01277-0.pdf
Accessed: 2026-11-09
Cited by: Findings citing this exhibit

Exhibit 451 · Accreditor letter

Letter, ECFA board chair Batts to Senator Grassley

In our view, churches, in general, would view annual filing with the IRS to be governmental intrusion into the most intimate recesses of church administration, including compensation practices.

Opposes requiring churches to file Form 990 or 990-N.

Source: Evangelical Council for Financial Accountability
Date: 21 April 2009
Quoted from: Michael E. Batts (ECFA board chair) to Sen. Grassley, 21 Apr 2009, p. 1
Grade: Primary record
Document: https://web.archive.org/web/20111216215654/http://finance.senate.gov/newsroom/ranking/download/?id=abb25810-a26e-4329-a4ed-424e692eb34f
Accessed: 2026-11-09
Cited by: Findings citing this exhibit
Note: The URL is an archived copy (Wayback Machine or UNT web archive); the issuer's original address is no longer the working copy.

Exhibit 452 · Accreditor report

Enhancing Accountability for the Religious and Broader Nonprofit Sector

He specifically asked ECFA to seek solutions that rely on self-regulation and not on new burdensome legislation.

Report to Grassley on compensation, clergy housing reporting, donor engagement; notes Driscoll cert denial (Oct 2012).

Source: Evangelical Council for Financial Accountability, Commission on Accountability and Policy for Religious Organizations
Date: December 2012
Quoted from: Message from the Chairman, p. 5
Grade: Primary record
Document: https://web.archive.org/web/2013/http://www.ecfa.org/PDF/Commission-Report-December-2012.pdf
Accessed: 2026-11-09
Cited by: Findings citing this exhibit
Note: The URL is an archived copy (Wayback Machine or UNT web archive); the issuer's original address is no longer the working copy.

Exhibit 453 · Accreditation standards

Seven Standards of Responsible Stewardship

Every organization shall be governed by a responsible board of not less than five individuals, a majority of whom shall be independent, who shall meet at least semiannually to establish policy and review its accomplishments.

Standard 1 requires a statement of faith affirming the evangelical Christian faith; Standards 2-6 govern board, audit, transparency and compensation.

Source: Evangelical Council for Financial Accountability
Date: 2024 (web page)
Quoted from: Standard 2
Grade: Primary record
Document: https://web.archive.org/web/2024/https://www.ecfa.org/Content/Standards
Accessed: 2026-11-09
Cited by: Findings citing this exhibit
Note: The URL is an archived copy (Wayback Machine or UNT web archive); the issuer's original address is no longer the working copy.

5.7 The warning letter of 6 March 2020

Finding REL-5.6Primary record

On 6 March 2020 the Food and Drug Administration and the Federal Trade Commission sent a joint warning letter to The Jim Bakker Show about silver products promoted for COVID-19. The letter states FDA's determination that the products are unapproved new drugs. The records found show no FTC court action.

The letter is addressed to James Bakker, The Jim Bakker Show, Blue Eye, Missouri. It states that "these products are intended to mitigate, prevent, treat, diagnose, or cure COVID-19 in people" and that FDA has determined they are unapproved new drugs sold in violation of the Federal Food, Drug, and Cosmetic Act. It asks for an email within 48 hours describing the steps taken.

Evidence: Exhibit 458

§5.7.1

The letter quotes a statement made on the program: "Silver Solution has been proven … to kill every pathogen it has ever been tested on …" The FTC paragraph states that it is unlawful under the FTC Act "to advertise that a product can prevent, treat, or cure human disease unless you possess competent and reliable scientific evidence."

§5.7.2

A warning letter requests correction and is not a court order. The record contains no FTC lawsuit against the show or its ministry. The court action in this record is the Missouri case described in the next section.

Exhibit 458 · Warning letter

Warning Letter to The Jim Bakker Show (MARCS-CMS 604820)

In addition, it is unlawful under the FTC Act, 15 U.S.C. 41 et seq., to advertise that a product can prevent, treat, or cure human disease unless you possess competent and reliable scientific evidence, including, when appropriate, well-controlled human clinical studies, substantiating that the claims are true at the time they are made

Joint letter on silver products marketed for COVID-19. A warning letter, not a court order.

Source: U.S. Food and Drug Administration and Federal Trade Commission
Date: 6 March 2020
Quoted from: FTC paragraph near end of letter
Grade: Primary record
Document: https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/jim-bakker-show-604820-03062020
Accessed: 2026-11-09
Cited by: Findings citing this exhibit
Note: The FTC took part through this joint letter. No FTC court action was found.

5.8 The Missouri consent judgment

Finding REL-5.7Primary record

On 22 June 2021 the Circuit Court of Stone County, Missouri entered a consent judgment in State ex rel. Schmitt v. Bakker. It bars the defendants from advertising or selling Silver Solution as a treatment for any disease, provides restitution of up to $115,766, and suspends a $50,000 civil penalty and $10,000 in costs. The defendants deny wrongdoing.

The Missouri Attorney General filed the petition on 10 March 2020 under the Missouri Merchandising Practices Act, and the case is No. 20SN-CC00084. The judge was Associate Circuit Judge Alan Blankenship. The defendants are Jim Bakker and Morningside Church Productions, which does business as the Jim Bakker Show Ministry.

Evidence: Exhibit 459

§5.8.1

The order enjoins the defendants under section 407.100.1 of the Missouri statutes from advertising or selling Silver Solution to diagnose, prevent, mitigate, treat or cure any disease or illness. It provides restitution of up to $115,766 to Missouri residents. The $50,000 civil penalty and the $10,000 in costs to the Attorney General are suspended on condition of compliance. Paragraph 20 requires Morningside to pay the Merchandising Practices Revolving Fund the difference between accepted refunds and $90,000.

§5.8.2

The judgment recites that the defendants have denied and continue to deny any and all allegations of wrongdoing and that they entered the consent judgment to avoid expense and the uncertainty of further litigation. The State alleged that the defendants misrepresented Silver Solution as a treatment for the coronavirus during television broadcasts between 12 February and 10 March 2020. The court made no finding on that allegation.

§5.8.3

The judgment describes the product as offered on the show in connection with the solicitation of contributions to Morningside Church. The judgment concerns one product and one ministry in one state.

Exhibit 459 · Court order (consent judgment)

State ex rel. Schmitt v. Bakker, No. 20SN-CC00084, Consent Judgment

Defendants shall pay the State of Missouri $50,000 in civil penalties pursuant to § 407.100.6, RSMo. The payment of civil penalties shall be suspended upon the condition that Defendants abide by all terms of this judgment.

Filed 22 June 2021. Enjoins advertising or selling Silver Solution to treat any disease (para. 18); restitution up to $115,766 (para. 19); Morningside to pay the Merchandising Practices Revolving Fund the difference between accepted refunds and $90,000 (para. 20); $50,000 civil penalty suspended on condition that defendants abide by the judgment (para. 21); $10,000 costs suspended (para. 22). Defendants deny wrongdoing (para. 10).

Source: Circuit Court of Stone County, Missouri (Hon. Alan Blankenship)
Date: 22 June 2021
Quoted from: Consent Judgment, para. 21 (scanned filing, page image checked)
Grade: Primary record
Document: https://web.archive.org/web/2021/https://ago.mo.gov/docs/default-source/press-releases/consent-judgment-bakker-signed.pdf
Accessed: 2026-11-09
Cited by: Findings citing this exhibit
Note: The URL is an archived copy (Wayback Machine); the issuer's original address is no longer the working copy.

5.9 Paycheck Protection Program loans

Finding REL-5.8Primary record

In SBA's loan-level Paycheck Protection Program files dated 30 September 2024, organizations coded NAICS 813110 (religious organizations) received 122,665 loans totaling $9.31 billion at initial approval, of which $9.09 billion was forgiven. The code covers all traditions, does not record denomination, and undercounts faith-based entities.

This project ran the query on SBA's PPP FOIA loan-level files on 9 November 2026. The result is the aggregate of every loan whose borrower SBA coded NAICS 813110. The query reports no individual borrower.

Evidence: Exhibit 467

§5.9.1

Method. The files at data.sba.gov/dataset/ppp-foia dated 30 September 2024 are one file of loans of $150,000 or more and twelve files of smaller loans. The query selected every row with the NAICS code 813110 and summed the initial approval amount and the forgiveness amount. The 11,468,210 rows total $796.8 billion in initial approvals.

PPP loans to borrowers coded NAICS 813110, SBA files dated 30 September 2024
Approved in	Loans	Initial approval
2020	90,230	$7.351 billion
2021	32,435	$1.960 billion
Total	122,665	$9.31 billion

§5.9.2

The loans were approved from April 2020 to August 2021. They amount to 1.07 percent of the loans in the file and 1.17 percent of its approval dollars. Of the $9.31 billion approved, $9.09 billion was forgiven, and 120,036 loans had forgiveness above zero. The median loan was $26,140.

§5.9.3

Three caveats apply. The code undercounts faith-based entities, because religious schools, hospitals, charities and social-service arms carry other codes. The file has 11.47 million rows against the 11.8 million loans that SBA reports for the program. The file records no denomination, and borrowers under the code include churches, synagogues, mosques, temples and other bodies. The figures show no tradition's share.

§5.9.4

PPP loans were a lawful program open to every eligible nonprofit. A loan to a religious organization is not evidence of any wrongdoing. No individual borrower is reported, because the available name-and-city matches do not establish identity.

Exhibit 467 · Loan-level dataset

SBA PPP FOIA loan-level data (files dated 30 Sep 2024)

Queried NAICS 813110 (Religious Organizations): 122,665 loans, $9,311,718,051.36 initial approval, $9,086,744,940.81 forgiven, among 11,468,210 file rows ($796.8 billion). Re-derived from the CSVs on 2026-11-09.

Source: U.S. Small Business Administration
Date: 30 September 2024
Grade: Primary record
Document: https://data.sba.gov/dataset/ppp-foia
Accessed: 2026-11-09
Cited by: Findings citing this exhibit
Note: Aggregate query only, run by this project on the CSV files dated 30 September 2024. NAICS 813110 undercounts faith-based entities. The file has 11,468,210 rows; SBA reports about 11.8 million loans.

Finding REL-5.9Primary record

The CARES Act created the Paycheck Protection Program and passed the Senate 96 to 0 on 25 March 2020, and President Trump approved it on 27 March 2020. President Biden approved the PPP Extension Act on 30 March 2021. SBA proposed removing its religious-status exclusions on 19 January 2021 and removed paragraph (k) of 13 CFR 120.110 in a final rule of 30 June 2022.

The Senate vote was Roll Call 80 of the second session of the 116th Congress: 96 yeas, 0 nays, 4 not voting. Section 1102 of the CARES Act makes eligible "any business concern, nonprofit organization, veterans organization, or Tribal business concern." The file records approvals in both 2020 and 2021.

Evidence: Exhibit 464, Exhibit 465, Exhibit 466, Exhibit 460, Exhibit 461, Exhibit 462, Exhibit 463

§5.9.5

SBA's interim final rule of 15 April 2020 (85 Fed. Reg. 20811) lists 501(c)(3) organizations as eligible and states that the ineligibility list in 13 CFR 120.110 applies "except that nonprofit organizations authorized under the Act are eligible." The rule of 8 May 2020 states that SBA regulations do not bar a religious nonprofit from making membership and employment decisions by religion.

§5.9.6

The proposed rule of 19 January 2021 (86 Fed. Reg. 5036), published under the Trump administration, states that SBA had told Congress on 3 April 2020 that two of its religious-status provisions were unconstitutional under Trinity Lutheran. It proposed removing five provisions. The final rule of 30 June 2022 (87 Fed. Reg. 38900), issued under the Biden administration and effective 1 August 2022, removed paragraph (k) of 13 CFR 120.110, which had excluded businesses principally engaged in teaching, instructing, counseling or indoctrinating religion. SBA kept the religious-use worksheet on Form 1971.

§5.9.7

The final rule reports 2,651 comments on that provision, over 99 percent of the comments received, and states that all but one opposed its removal. SBA issued its April and May 2020 rules and its January 2021 proposal under President Trump, and its June 2022 final rule under President Biden.

Exhibit 464 · Statute

CARES Act, Pub. L. 116-136, section 1102

any business concern, nonprofit organization, veterans organization, or Tribal business concern described in section 31(b)(2)(C) shall be eligible to receive a covered loan

Creates PPP; makes nonprofit organizations eligible if 500 or fewer employees. Senate passed 96-0 on 25 Mar 2020 (Roll Call 80); approved 27 Mar 2020.

Source: U.S. Congress
Date: 27 March 2020
Quoted from: Sec. 1102, new 7(a)(36)(D)(i)
Grade: Primary record
Document: https://www.govinfo.gov/content/pkg/PLAW-116publ136/html/PLAW-116publ136.htm
Accessed: 2026-11-09
Cited by: Findings citing this exhibit

Exhibit 465 · Roll-call vote

U.S. Senate Roll Call Vote 116-2-80, H.R. 748

YEAs 96 NAYs 0 Not Voting 4

Bill passed: YEAs 96, NAYs 0, Not Voting 4.

Source: U.S. Senate
Date: 25 March 2020
Quoted from: Vote counts
Grade: Primary record
Document: https://www.senate.gov/legislative/LIS/roll_call_votes/vote1162/vote_116_2_00080.htm
Accessed: 2026-11-09
Cited by: Findings citing this exhibit

Exhibit 466 · Statute

PPP Extension Act of 2021, Pub. L. 117-6

is amended by striking ``March 31, 2021'' and inserting ``June 30, 2021''

Extends PPP application period; approved 30 Mar 2021.

Source: U.S. Congress
Date: 30 March 2021
Quoted from: Sec. 2(a), 135 Stat. 250
Grade: Primary record
Document: https://www.govinfo.gov/content/pkg/PLAW-117publ6/html/PLAW-117publ6.htm
Accessed: 2026-11-09
Cited by: Findings citing this exhibit

Exhibit 460 · Federal Register rule

SBA Interim Final Rule, Paycheck Protection Program, 85 FR 20811

except that nonprofit organizations authorized under the Act are eligible.

Eligibility includes 501(c)(3) nonprofits; ineligibility list in 13 CFR 120.110 applies 'except that nonprofit organizations authorized under the Act are eligible.'

Source: U.S. Small Business Administration
Date: 15 April 2020
Quoted from: para. c, 'How do I determine if I am ineligible?'
Grade: Primary record
Document: https://www.govinfo.gov/content/pkg/FR-2020-04-15/pdf/2020-07672.pdf
Accessed: 2026-11-09
Cited by: Findings citing this exhibit

Exhibit 461 · Federal Register rule

SBA Interim Final Rule, PPP Nondiscrimination and Additional Eligibility Criteria, 85 FR 27287

SBA regulations do not bar a religious nonprofit entity from making decisions with respect to the membership or the employment of individuals of a particular religion

Religious nonprofit borrowers may make membership and employment decisions by religion.

Source: U.S. Small Business Administration
Date: 8 May 2020
Quoted from: p. 27288
Grade: Primary record
Document: https://www.govinfo.gov/content/pkg/FR-2020-05-08/pdf/2020-09963.pdf
Accessed: 2026-11-09
Cited by: Findings citing this exhibit

Exhibit 462 · Federal Register proposed rule

SBA Proposed Rule, Ensuring Equal Treatment for Faith-Based Organizations, 86 FR 5036

they categorically disqualify otherwiseeligible faith-based organizations from receiving business loan funds and disaster assistance solely on account of their religious status.

Proposes removing five religious-status exclusions; recounts SBA's 3 Apr 2020 28 U.S.C. 530D letter.

Source: U.S. Small Business Administration
Date: 19 January 2021
Quoted from: Background B (text as extracted)
Grade: Primary record
Document: https://www.govinfo.gov/content/pkg/FR-2021-01-19/pdf/2021-00446.pdf
Accessed: 2026-11-09
Cited by: Findings citing this exhibit

Exhibit 463 · Federal Register final rule

SBA Final Rule, 13 CFR 120.110(k) removed and reserved, 87 FR 38900

paragraph (k) of section 120.110 should be removed from the Agency's regulations, and reserved

Removes the exclusion of businesses principally engaged in teaching or indoctrinating religion; effective 1 Aug 2022; keeps SBA Form 1971 religious-use worksheet.

Source: U.S. Small Business Administration
Date: 30 June 2022
Quoted from: Preamble, response to comments
Grade: Primary record
Document: https://www.govinfo.gov/content/pkg/FR-2022-06-30/pdf/2022-13483.pdf
Accessed: 2026-11-09
Cited by: Findings citing this exhibit

5.10 The Pew survey of 2006

Finding REL-5.10Primary record

Pew's 2006 ten-country survey found that 46 percent of U.S. respondents agreed that God will grant material prosperity to all believers who have enough faith: 66 percent of Pentecostals, 59 percent of charismatics and 43 percent of other Christians.

The item was worded "God will grant material prosperity to all believers who have enough faith." Respondents could answer completely agree, mostly agree, mostly disagree or completely disagree, and the table counts those who agreed. The U.S. base was 681 respondents who identify with a religion or believe in God.

Evidence: Exhibit 468

§5.10.1

The report states that the belief is common among Christians in each of the ten countries. In nine of the ten countries most Pentecostals agreed. The U.S. sample was a national telephone sample in English and Spanish, fielded 20 July to 7 September 2006 by Princeton Survey Research Associates International. The margin of error was 4 percent for the general public and 9 percent for Pentecostals.

§5.10.2

The survey asked about belief and did not ask about ministry finances.

Exhibit 468 · Survey report

Spirit and Power: A 10-Country Survey of Pentecostals

God will grant material prosperity to all believers who have enough faith.

U.S. 46 percent of respondents (n=681) agreed; Pentecostals 66, charismatics 59, other Christians 43. Fieldwork US 20 Jul-7 Sep 2006.

Source: Pew Forum on Religion & Public Life (Pew Research Center)
Date: 5 October 2006
Quoted from: p. 29 (item f)
Grade: Primary record
Document: https://www.pewresearch.org/wp-content/uploads/sites/7/2006/10/pentecostals-08.pdf
Accessed: 2026-11-09
Cited by: Findings citing this exhibit

5.11 What remains open

§5.11.1

No cited document shows that a ministry's revenue rose while a problem persisted.

§5.11.3

The 1988 IRS revocation of the PTL exemption is known only through the staff memo. No Supreme Court review of the Seventh Circuit's decision in Gaylor is recorded.

§5.11.4

The Senate inquiry and the Bakker case concern Protestant media ministries. The release states that the committee also received reports about other churches and religious organizations, and the staff memo states that the committee did not contact those organizations directly. No regulator order across traditions was found.

Key findings

The ranking member of the Senate Finance Committee wrote to six media-based ministries on 5 November 2007 and asked for financial information (5.1).
The committee's own account shows two full responses and four that were partial, nonresponsive or declined (5.2).
Staff issued no subpoenas and gave three reasons (5.3).
The January 2011 materials are a staff memorandum, not a committee report, and Grassley asked ECFA whether the issues can be addressed without legislation (5.4).
Staff could not determine whether four churches paid taxes on income earned in related entities, because the churches did not supply tax information (5.5).
FDA and FTC sent a joint warning letter on 6 March 2020 about silver products promoted for COVID-19 (5.6).
A 2021 Missouri consent judgment bars the sale of Silver Solution as a disease treatment, and the defendants deny wrongdoing (5.7).
Organizations coded as religious received 122,665 PPP loans totaling $9.31 billion, under a lawful program open to all eligible nonprofits (5.8).
Congress enacted PPP by a 96 to 0 Senate vote, and the Trump and Biden administrations both administered its religious-eligibility rules (5.9).
Pew's 2006 survey found that 46 percent of U.S. respondents agreed that God will grant material prosperity to believers with enough faith (5.10).

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