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§3.3 MEANING OF CHARITABLE ORGANIZATIONReligious Organizations. Organizations that are considered religious for purposesof the law of charitable giving 314 include:• Churches, synagogues, and similar places of worship 315• Conventions and associations of churches 316• Integrated auxiliaries of churches 317• Church-run organizations, such as schools, hospitals, orphanages, nursinghomes, publishing entities, broadcasting entities, and cemeteries• Religious orders• Apostolic groups 318• Missionary organizations• Bible and tract societiesThe courts and the IRS traditionally have been reluctant to rule on whetheran organization is a church or the like or a religious entity, if only because of concernabout constitutional law constraints. This reluctance is dissipating, however,and the IRS and the courts are developing criteria for defining churchesand other religious organizations.Scientific Organizations. Organizations that are considered scientific for purposesof the law of charitable giving 319 include:• Organizations that are engaged in scientific research 320• Organizations that are otherwise operated for the dissemination of scientificknowledge (such as publishing entities) 321There are several other categories of charita-Other Charitable Organizations.ble organizations: 322• Literary organizations 323• Organizations that seek to prevent cruelty to children or animals 324• Cooperative hospital service organizations 325314 The law underlying these categories is discussed in Tax-Exempt Organizations ch. 8.315 IRC § 170(b)(1)(A)(i). A charitable deduction was denied an individual who claimed to be a church becauseof belief in the Bible; the gifts were made to himself. The court said that a church cannot, for federal incometax purposes, consist of just one individual, in that the law requires a “group of people gathering together aspart of an organized entity.” Richardson v. Commissioner, 70 T.C.M. (CCH) 14, 16 (1995). Otherwise, thecourt added, “every individual taxpayer in the United States might declare himself to be a church in an attemptto avoid paying Federal income tax.” Id.316 Richardson, 70 T.C.M. at 16.317 Id.318 IRC § 501(d).319 The law underlying these categories is discussed in Tax-Exempt Organizations ch. 9.320 Reg. § 1.501(c)(3)-1(d)(1)(i)(c).321 Id.322 The law underlying these categories is discussed in Tax-Exempt Organizations ch. 10.323 Reg. § 1.501(c)(3)-1(d)(1)(i)(e).324 Reg. § 1.501(c)(3)-1(d)(1)(i)(g).325 IRC § 501(e). 101