Rev. Rul. 74-224

Advice has been requested whether an organization which has a membership comprised of churches of various denominations qualifies as an "association of churches" within the meaning of section 170(b)(1)(A)(i) of the Internal Revenue Code of 1954 for purposes of classification as an organization described in section 509(a)(1).

The organization is recognized as exempt under section 501(c)(3) of the Code and was created to act as the coordinating agency for its member churches for the purposes of developing the spirit of Christian fellowship and cooperative mission among the denominations and churches in a particular geographical area and to promote through cooperative effort the spiritual, moral, social, and civic welfare of the area. Membership is comprised of Catholic and Protestant Churches of various denominations. The Governing Board of the organization consists of two voting members from each Church.

The organization engages in a number of activities such as provision of clergymen at hospitals and college campuses, pastoral counseling, coordinated religious educational programs and facilities, and coordinated efforts to aid the poor. Support for the organization is primarily derived from its members and public contributions.

Section 509(a)(1) of the Code provides that the term "private foundation" does not include an organization described in section 170(b)(1)(A) (other than in clauses (vii) and (viii)). An organization is described in section 170(b)(1)(A)(i) if it is a church or a convention or association of churches. Neither the Code nor the regulations thereunder define what constitutes a convention or association of churches.

Although the term "convention or association of churches" has a historical meaning generally referring to a cooperative undertaking by churches of the same denomination, nothing in the legislative or religious history of the term prevents its application to a cooperative undertaking by churches of differing denominations, assuming such convention or association otherwise qualifies for recognition of exemption as an organization described in section 501(c)(3). The term is not limited in its application to a group of churches of the same denomination. Accordingly, the organization described herein is an association of churches within the meaning of section 170(b)(1)(A)(i) of the Code for purposes of classification as an organization described in section 509(a)(1).