The Internal Revenue Service (IRS) has denied tax-exempt status to a Christian non-profit coffee shop that intended to donate 100 percent of its profits to ministries and charitable organizations and function as a missional space for evangelism to non-believers.
The private letter ruling is redacted, so the location of the coffee shop and those involved are unknown.
The vision of the coffee shop was for it to be a place "where believers could interact with non-believers in a safe and friendly environment to convey the Gospel in a non-confrontational manner in word and deed,” the ruling stated.
While one of the pastors from the local church helped to co-found the coffee shop and the pastor’s church contributed financially in starting up the shop, it was founded as a separate entity from the church “in order to encourage other Christian churches and organizations to participate in [the] vision.”
The ruling specifies that the coffee shop would give away 100 percent of its profits to "community ministries, other local, national or international non-profits or organizations, or those in financial need."
The IRS, however, determined that the coffee shop did not qualify as a 501(c)(3) organization because its function bears too close of a resemblance to that of a for-profit coffee shop and concluded that its operation was a “commercial activity, not a charitable activity.”
While the coffee shop intends to donate its funds to charitable organizations, the “primary activity is the operation of a coffee shop in a commercial manner,” the ruling asserted.
According to Christian Post, Colossae Church in Oregon runs its own coffee shop with two other organizations -- Well & Good Coffee House -- and donates 100 percent of its profits toward the city.
"The bottomline is that [such] a 501(c)(3)'s primary function has to be religious,” pastor of Colossae Church Chuck Bomar told the Christian Post.
"The heart behind it doesn't matter to the government. It is a daily function that matters," Bomar continued. "Because the daily function isn't religious, the heart of it doesn't matter in the corporate structure of it."
The church has the right to file a protest for tax-exempt status.