By Grant Williams
The Chronicle of Philanthropy
May 13, 2008
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In a ruling that could have implications for many charities, the Internal Revenue Service has denied a tax exemption to an organization in part because the group did not spend enough of its money on charitable programs.
This is the first public sign that the revenue service is measuring how much charities spend by using a controversial approach that the government has recently decided to apply.
The IRS said the organization did not carry on a charitable program “commensurate in scope” with its financial resources.
As is its policy, the IRS did not identify the group. But the organization was identified as the National Foundation of America, in Franklin, Tenn., by the Web site of a state government receiver in Tennessee who has been closing the organization.
The IRS ruling was released at a time when the tax agency has been signaling that it plans to take a more-aggressive approach to making sure the nation’s nonprofit organizations are not hoarding or wasting money.
Steven T. Miller, commissioner of the IRS’s tax-exempt and government-entities division, said in a speech last month that the agency would apply a standard that it had briefly embraced years ago but then set aside — a so-called commensurate test — to help determine whether charities were spending money efficiently and effectively.
Less Than 1% to Charity
In its private-letter ruling the IRS said the organization had said in its application for tax-exempt status that it planned “to coordinate and conduct, through its staff, evangelistic campaigns in a number of countries wherein the people are receptive to the Gospel of Jesus Christ.” The group’s initial two-person board of directors was a husband and wife.