United States v. Christian Echoes Ministry, 404 U.S. 561 (1982)

APPEAL FROM THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF OKLAHOMA

Syllabus

Appellee, a nonprofit religious corporation, brought this refund suit, claiming that it was entitled to tax exempt status under § 501(c)(3) of the 1954 Internal Revenue Code. The District Court held that, under the facts adduced at trial, appellee qualified for exemption. It went on, however, to conclude that the Internal Revenue Service (IRS), in revoking that exemption, violated (1) free exercise requirements by analyzing each activity of appellee and classifying it as "religious" or "political," and (2) due process requirements by singling appellee out, among all other religious organizations, for investigation and exemption revocation without supporting evidence.

Held: This Court has no jurisdiction to entertain the direct appeal that the Government seeks to take under 28 U.S.C. § 1252 from the District Court’s decision, which did not hold § 501(c)(3) unconstitutional as a whole or as applied, but was merely directed at the method and means by which the IRS enforced § 501(c)(3) in this case.

Vacated and remanded.