## Facts

- VIA was a California organization centered on wellness and member mentoring.
- Individuals became members by paying a small membership fee.
- Membership entitled participants to tailored fitness programs and home visits from trained VIA “mentors.”
- VIA characterized the home visits as “worship,” describing the sharing and learning of information during visits as spiritual learning.
- During home visits, mentors led a group meditation practice that VIA called “harmonization.”
- The home visits were optional and scheduled irregularly rather than held on a fixed, recurring basis.
- VIA held no other meetings with members besides these home visits.
- VIA applied to the IRS for recognition as a “church” for federal tax purposes.
- The IRS denied VIA’s application, and VIA petitioned the United States Tax Court to review that determination.

## Issues

1. Whether VIA qualified as a “church” for federal tax purposes, such that the IRS was required to recognize it as a church.
2. Whether, based on VIA’s structure and activities, the IRS properly denied VIA’s request for church recognition.

## Decision

- The Tax Court sustained the IRS’s denial of VIA’s request for recognition as a church.
- The court concluded that VIA’s activities and organizational characteristics did not satisfy the indicia generally associated with a church for federal tax purposes.
- VIA was not entitled to the requested determination treating it as a church.

## Legal Principles

- Classification as a “church” for federal tax purposes turns on the organization’s overall characteristics and operations, not solely on labels it uses for its activities.
- In deciding church status, the IRS and courts commonly consider multiple, nonexclusive factors associated with churches (often drawn from administrative guidance and prior cases), including items such as:
  - regular religious services;
  - a regular congregation and opportunities for congregational worship;
  - an established place (or established manner) of worship and recurring worship gatherings;
  - an organized ministry or comparable religious leadership structure; and
  - a recognizable creed, doctrine, or form of worship reflected in the group’s practice.
- Optional, irregular, individualized gatherings—without recurring services or a stable congregational community—tend to weigh against church classification.
- An organization’s primary day-to-day function matters: programs that look chiefly like wellness, fitness, or personal-development services are less likely to be treated as a church absent other church-like attributes.
- In a Tax Court review of an IRS denial of church recognition, the court evaluates whether the applicant meets the applicable federal standards for church status based on the record presented.

## Conclusion

VIA offered members fitness programming and optional, irregular home visits led by mentors that included discussion and a meditation practice called harmonization, and it held no other member meetings. When the IRS denied VIA’s request to be recognized as a church, VIA sought review in the Tax Court. The Tax Court upheld the IRS’s determination, finding that VIA’s structure and activities did not reflect the characteristics generally associated with a church for federal tax purposes.


VIA v. Commissioner, T.C. Memo. 1994-349 (1994)