CHRISTIANITY, INC.

THhe Truth About Church Incorporation and 501(c)(3) Status

by Greg Loren Durand
Good and Lawful Christian Man

The Church is Christ's Corporation

Most churches in America have incorporated and have obtained 501(c)(3) status from the Internal Revenue Service. Incorporation has become so common that such a practice is rarely questioned, and to speak out publicly against incorporation will often subject the critic to immediate censure and verbal abuse. It has even come to the attention of this writer that the General Assembly of a well-known, and incorporated, Reformed denomination declined to establish fraternal relations with another Reformed denomination on the basis of the latter's failure to incorporate. This is, in effect, to refuse to acknowledge the denomination as a true church of Christ because it has not bowed its knee to Caesar (the State). Such distorted thinking is shocking, but unfortunately it is commonplace.

So what exactly is incorporation? What really happens to a church that becomes incorporated? Are there biblical principles against incorporation?

First of all, let us define the word "corporation." In the strict everyday definition of the word, a corporation is "a group of people combined into or acting as one body." (1) This word is derived from the Latin word "corpus," which means "body." In this sense, the Christian Church is indeed a corporation. It is the "corpus Christi," the "Body of Christ." It derives its existence and authority from its Head, the risen and victorious Son of God. It is comprised of individual members who have covenanted together to further Christ's Kingdom by the preaching of the Gospel and the discipling of the nations (Matthew 28:19-20).

The Church's "corporate status" is well-established in Scripture:

For as the body is one and has many members, but all the members of that one body, being many, are one body, so also is Christ. For by one Spirit we were all baptized into one body-- whether Jew or Greeks, whether slaves or free-- and have all been made to drink into one Spirit. For in fact the body is not one member but many.... Now you are the body of Christ, and members individually (I Corinthians 12:12-14, 27).
...Christ is the head of the church; and He is the Savior of the body.... For we are members of His body, of His flesh and bones (Ephesians 5:23b, 30).
[Christ is] the Head, from whom all the body, nourished and knit together by joints and ligaments, grows with increase which is from God (Colossians 2:19).

The Church is the visible manifestation of Christ's Kingdom on earth. However, as Jesus Himself stated, "My Kingdom is not of this world" (John 18:36). Many Christians have misunderstood this verse to mean that neither the Church nor individual Christians should involved themselves with the affairs of the world. In what is known as "pietism," a false dichotomy is erected between the "spiritual" Kingdom and the "carnal" world.

Of course, this is not what Jesus had in mind at all. He very explicitly stated elsewhere that Christians are to act as "salt" and "light" in the world by permeating society and working to change it from within (Matthew 5:13-16). This task of dominion is accomplished through the work of evangelism and discipleship, as Jesus commanded in the Great Commission. The Christian's purpose is indeed "worldly," insofar as it is involved in bringing the world into subjection to the Word of God (cf. II Corinthians 10:5).

Thus, the true meaning of Jesus' declaration that His Kingdom is "not of this world," is that it does not derive its authority and power from the world or its institutions. The Church is indeed a spiritual organization, but this simply means that it is "of the Spirit"-- it relies upon the Holy Spirit and the inspired Word for its existence, not upon the efforts or laws of men. This important detail should be kept in mind as we further study the subject of church incorporation.

The State is Sovereign Over its Corporations

Having briefly examined the biblical definition of a corporation, let us now look at the legal definition of a corporation. According to the U.S. Supreme Court:

A corporation is a creature of the state. It is presumed to be incorporated for the benefit of the public. It receives certain special privileges and franchises and holds them subject to the laws of the state and the limitation of its charter. Its powers are limited by law. It can make no contract not authorized by its charter. Its rights to act as a corporation are only preserved to it so long as it obeys the laws of its creation. There is a reserved right in the legislature to investigate its contracts and ascertain if it has exceeded its powers. (2)

In Black's Law Dictionary we find a similar definition:

[A corporation is] an artificial person or legal entity created by or under the authority of the laws of a state. An association of persons created by statute as a legal entity.... The corporation is distinct from the individuals who comprise it (shareholders).... Such an entity subsists as a body politic under a special denomination, which is regarded in law as having a personality and existence distinct from that of its several members.... (3)

The laws dictating incorporation are very specific:

A corporation derives its existence and all of its powers from the State and, therefore, has only such powers as the State has conferred upon it. Power is used here to mean the legal capacity to execute and fulfill the objects and purposes for which the corporation was created, and the source of this power is the charter and the statute under which the corporation was organized. (4)
Corporate existence is a privilege granted by the sovereign upon compliance with specified conditions. (5)

Every corporation has obtained a charter from the State of Incorporation. This charter is simply permission to exist given to the corporation, without which, its operations would be considered illegal. In addition to the charter are the articles of incorporation:

The objects or purposes for which a corporation is formed are expressly stated in its articles of incorporation, which delineate in general language the type of business activities in which the corporation proposes to engage. (6)

In Smith and Roberson's Business Law, we read:

Instances of non-profit corporations are educational institutions, athletic clubs, library clubs, fraternities, sororities, hospitals, and organizations which have exclusively a charitable purpose. (7)

The reader will notice that "churches" are conspicuously absent from this list of non-profit corporations. That is because our law-makers, godless as they may be, are fully aware that incorporation involves creation, and the Church simply cannot be created by the State. Furthermore, the Church's ordained purpose of preaching the Gospel can never be illegal, so no special license is required from the State to do so.

Though not all of our founding fathers were genuine Christians, they nevertheless understood that the Church of Christ is under the sole jurisdiction of its Lord, and that the civil magistrate therefore should not dare to encroach upon that authority. Because of this healthy respect for the Church, the very first sentence of the Bill of Rights reads as follows:

Congress shall make no law regarding an establishment of religion, or prohibiting the free exercise thereof. (8)

According to Supreme Court Justice Hugo Black:

The "establishment clause" of the First Amendment means at least this: Neither a state nor the federal government can set up a church. (9)

It was one of the principles of the sixteenth-century Reformation that the Church and the State are separate governments, and that, although they are to work together for the furtherance of God's Kingdom, they are not to either merge with one another or usurp the sphere of authority of one another. (10) The Church is forbidden by Scripture to take up the State's "sword" (Romans 13:4), and the State is likewise forbidden to assume the Church's "keys" (Matthew 16:19). However, as we will see, the latter is precisely what occurs whenever a church seeks incorporation at the hands of the State.

The Incorporated Church and the IRS

It has been claimed by some that church incorporation is necessary in order that the government may distinguish between true and false churches. However, it is not the job of the State to make judgments regarding such issues; its only purpose is to "execute [God's] wrath on him who practices evil" (Romans 13:4).

Though not technically a government agency, the Internal Revenue Service nevertheless operates under federal authority and therefore cannot make any judgments regarding a church until the church voluntarily surrenders its sovereignty. Few people realize that the Internal Revenue Service's very name defines the limits of its authority. Ever since the Federal Reserve Act was passed in 1913, the IRS has been authorized by Congress to collect taxes connected with revenue which is internal to the federal government (the District of Columbia). It therefore has no authority external to Washington D.C., and its statutes are not binding upon any person or organization within the several states, including a church. Consequently, according to the Internal Revenue Code (Title 26 of the United States Code), a church, its integrated auxiliaries, and conventions and associations of the church are excluded from taxation. (11) It should be noted that exclusion is a right that is retained by a sovereign entity, while exemption is a privilege that is granted by a sovereign entity to a lesser entity. As such, they are not synonymous terms.

Elsewhere, the IRS states:

Although a church, its integrated auxiliaries, or a convention of churches is not required to file Form 1023 to be exempt from federal income tax or to receive tax deductible contributions, such an organization may find it advantageous to obtain recognition of exemption. (12)

Just what "advantage" is there for a church in obtaining 501(c)(3) recognition and thereby exchanging its sovereignty for a subordinate status in relation to the federal government? Most people would answer that such grants the church exemption from taxation. However, we have already seen that the federal government has never been able to tax the Church of Christ; the Church is not exempt from taxation, it is immune. The "advantage" is something else entirely:

By establishing its exemption, potential contributors are assured by the [Internal Revenue] Service that contributions will be deductible. (13)

The average person in America today is taxed so heavily that offerings in the church's collection plate would no doubt suffer greatly if the tax-deduction incentive is not made available. If we look closer, we can see a clear pattern develop. The minister of an incorporated church preaches on the duty of each congregant to pay "his fair share of taxes" (which amounts to about 48% of the average income). After being led to believe that our current federal tax system is positive law (14) and therefore must be obeyed by everyone (which it is not), the members of the church seek some kind of financial relief in itemizing their tithes and offerings on their tax returns. This in turn justifies the continued usage by the church of the 501(c)(3) status. This is not to say that such a cycle is deliberately begun by the ministers and elders of the incorporated church, but begun it is nevertheless. The tragic irony of all this is that, according to the Internal Revenue Code, financial donations to an unregistered, unincorporated church are automatically tax-deductible. (15)

The IRS, of course, knows very well that it has no constitutional authority over the Church, and that it may not violate the First Amendment protection against government interference with the Church. In fact, the IRS may not violate the constitutional rights of any American Citizen or group of Citizens, and is able to gain jurisdiction only when such is given to it voluntarily. Thus, the IRS holds out the unbiblical "advantage" of 501(c)(3) corporate status as bait to clergy ignorant of the law in hopes that these men will "bite," thereby placing themselves and their congregations firmly on its jurisdictional hook.

Once the bait has been taken, and the catch is reeled in, another church has been transformed into a "legal fiction" subject to the tyrannical control of the federal government. The IRS prohibits such organizations from "carrying on propaganda, or otherwise attempting to influence legislation...." (16) This prohibition extends, not only to the endorsement of a political candidate, but also any other attempts to "influence legislation," including taking a public stand against such politically-protected abominations as abortion or homosexuality.

Should the Bible itself one day be ruled by the government to be "politically incorrect," incorporated churches will find themselves on the horns of a very serious dilemma. After all, in a civil suit, a corporation's defense is limited to the terms specifically enumerated in its charter and articles of incorporation. All other "extrinsic evidence," including the Bible or any historical Christian creeds or standards, will be disallowed in a State court case, because they are "not contained in the body of [the] contract." (17) Outside of its own walls, the incorporated church may not stand on the authority of the Scriptures regarding any political or civil issue, because it is bound by the "higher laws" of the State. Consequently, the Christian Church in America little by little ceases to be the "salt" and "light" to society that it was commanded to be. And all this for a simple tax deduction.

The Incorporated Church is Judged by the State

The astute reader will begin to see at this point the direction this article is taking. If a corporation "derives its existence and all of its powers from the State," can a Christian church seek such a status without violating Scripture? The answer is, unfortunately, not always clear to those church leaders who have either incorporated their churches, or plan to do so. According to the session of one particular church:

The use of this church of legal vehicles to relate to the civil government including, but not limited to, the use of IRS 501(c)(3) status, is done in recognition of the practical necessity of a method by which civil government entities may carry out their responsibility of distinguishing legitimate churches for purposes of recognizing such church's tax immunity and other legal protection, while at the same time retaining their ability to prevent fraudulent groups from calling themselves churches to avoid taxation, etc. The use of such vehicles by Providence Presbyterian Church is not meant to imply that we are agreeing to the idea that the church exists as a creation of or an entity of the state, or that the church is an institution subordinate to the state; nor is it meant to imply that the civil government has the authority to tax the church, or to regulate its doctrine or Biblically-based practice. Rather, we hold that each is an entity which as to its existence and operation answers directly to God and not to the other. (18)

Such a statement, though well-intentioned and, to some extent, biblically accurate, is unfortunately demonstrative of the most deplorable legal naivete. Simply adopting this statement into the by-laws of the church will not change the legal status of the corporation from a "creature of the state" to a true body of Christ. The reader will notice the inherent contradiction between the claim that the IRS has a "responsibility of distinguishing legitimate churches" and the denial that the "church is an institution subordinate to the state" and that it may "regulate its doctrine or Biblically-based practice." Any time the IRS, or the federal government in general, takes upon itself the "responsibility" of judging the legitimacy of any Christian organization, it has, in fact, assumed the position of superiority. Only a superior entity or standard may judge the actions or beliefs of another.

Operating as a Government Business

There are profit-making businesses and there are non-profit businesses, but a business is a business in the eyes of the government. An incorporated church simply cannot deny the fact that it has requested permission of the State to operate as a business. Not only does it have its charter and articles of incorporation on file with the Secretary of State, but it is also required to list a President, Vice-President, Secretary, and Treasurer. None of these offices were instituted by Christ in His Church (cf. Ephesians 4:11-12), because they exist to control the business dealings of a corporation, not the sacramental duties of the Body of Christ.

It is also interesting to note that many churches since 1984 have begun to list the minister and other ecclesiastical leaders as "employees" for Social Security purposes. (19) In this regard, a Form W-2 is issued to the minister enumerating his "gross income." As we have seen, the IRS exists to regulate revenue which is internal to the federal government. Consequently, in the Internal Revenue Code, an "employee" is specifically defined as follows:

...[T]he term 'employee' includes [means] an officer, employee, or elected official of the United States [the federal government], a State [a federal territory, not one of the several states of the Union], or any political subdivision thereof.... (20)

The term "gross income" also has very specific parameters. In the Internal Revenue Code we are told that taxable income is that "which is effectively connected with the conduct of a trade or business within the United States [the District of Columbia or one of its political subdivisions]." (21) Elsewhere in the IRC, "trade or business" is defined as "the performance of the functions of a public office." (22) By listing the minister as an "employee" who earns "income," the incorporated church is unknowingly identifying him as one who works for the federal government. It is therefore not surprising that the minister of an incorporated church is often the one who accepts the title of "registered agent," which is "one who represents and acts for another under the contract or relation of agency." (23) As such, he is the representative of the State to the corporation, as opposed to a "corporate agent," who is "authorized to act for a corporation...." (24)

Subject to Taxation Via Social Security

Yet another indication that an incorporated church is a government agency is its participation in Social Security. It is not a well-known fact that Social Security "contributions" are just another form of direct taxation and the funds received by the federal government via the Federal Insurance Contributions Act (FICA) are "set apart to no special use and subject to be applied to any congressional appropriation." (25) Seen in this light, payment into Social Security by incorporated churches brings us to an astonishing conclusion: 501(c)(3) churches are not exempt from taxation after all. It is an established legal principle that "the power to tax is the power to destroy." The government only has the power to destroy that which it has created. If churches wish to incorporate and thereby have their ministers treated as "employees" and their salaries as "income" subject to FICA taxes, then they should at least be honest with their congregations and stop attempting to deny that they are "political subdivisions" of Washington D.C. and "internal" to the federal government.

Another related issue here is that of the "corporate franchise." According to law, "a corporation must have a franchise." (26) In the case of an incorporated church, who are its franchises? If you guessed the members of the congregation, you are correct. In fact, they are legally "shareholders" in the business. This is proven by the fact that the so-called "congregational meetings" of the incorporated church must follow the legal guidelines of any other corporate meeting. For example, motions must be made and minutes must be kept of the proceedings. By-laws must be maintained and any additions (amendments) must be voted on by the members of the church.

Furthermore, at the end of the year, members and contributors will receive an itemized report of their financial contributions to the church for tax purposes. One particular church known to this writer recently distributed contribution records that showed a beginning and ending "balance" for each member. This practice directly contradicts the Bible's commands regarding giving to the Lord's work:

Take heed that you do not do your charitable deeds before men, to be seen by them. Otherwise you have no reward from your Father in heaven. Therefore, when you do a charitable deed, do not sound a trumpet before you as the hypocrites do in the synagogues and in the streets, that they may have glory from men. Assuredly, I say to you, they have their reward. But when you do a charitable deed, do not let your left hand know what your right hand is doing, that your charitable deed may be in secret; and your Father who sees in secret will Himself reward you openly (Matthew 6:1-4).

The pastor of an incorporated church may therefore inform the congregation of the tax-deductibility of their gifts only if he warns them that a tax write-off may be the only reward they will receive.

The Incorporated Church Surrenders its Rights

It is a common belief that an incorporated church may refuse to disclose its financial records, particularly its tithing records, to the State should such be demanded. However, such a naive belief will not protect the church or its members from harassment from the Internal Revenue Service or any other federal agency:

...[A] corporation is not considered as a person within that clause of the fifth amendment to the constitution which protects a "person" against self-incrimination. (27)

According to the ruling of the Supreme Court in Hale v. Henkel:

There is a clear distinction in this particular between an individual and a corporation and that the latter has no right to refuse to submit its books and papers for an examination at the suit of the State....
It would be a strange anomaly to hold that a State, having chartered a corporation to make use of certain franchises, could not, in the exercise of its sovereignty, inquire how these franchises had been employed, and whether they had been abused and demand the production of the corporate books and papers for that purpose.
While an individual may lawfully refuse to answer incriminating questions unless protected by an immunity statute, it does not follow that a corporation vested with certain privileges and franchises, may refuse to show its hand when charged with an abuse of such privileges. (28)

In other words, a corporation has no rights, only privileges which may be revoked any time its creator sees fit. Individual members ("share-holders" or "corporate franchises") also surrender their rights on account of their legal union with the corporation. Thus, the IRS may audit the corporation's financial records at any time, because, as one former IRS commissioner stated, "The churches... hold in trust that which belongs to the government." (29) This is the law, and it cannot be changed by amendments to church by-laws, or even by the good intentions of church leaders.

Can an incorporated church refuse to disclose its financial records to the IRS on the grounds that it did not know that such consequences would arise from incorporation? Unfortunately, the answer is no. Incorporation is a form of "non-positive," or "contract law." According to Black's Law Dictionary, a contract is "an agreement between two or more persons which creates an obligation to do or not to do a particular thing." (30) The laws comprising the contract do not apply to either party until the contract is agreed upon, at which time it is legally binding upon both. Claiming ignorance of the specifics of the contract will not excuse either party from their obligation once the contract is signed:

As a general proposition, a party is held to what he signs.... One cannot obtain a release from contract liability upon the ground that he did not understand the legal effect of the contract. (31)

By incorporating, the pastor and elders of a church need to realize that they have, in effect, signed a contract with the federal government which they have become legally and morally liable to obey (cf. Romans 13:1). They cease to exist as a "real" First Amendment association with "unalienable" rights, and are transformed into a federal institution under the complete jurisdiction and control of "Acts of Congress." A church can no more change the nature of a contract after the fact than a private individual may do so.

The Unbiblical Status of Limited Liability

Finally, let us take a brief look at the biblical problems of church incorporation. As we have seen, the Bible teaches that the Christian Church is a spiritual corporation that derives its existence from its Head, who is Christ. Each individual member is in covenant with the others and exercises his or her gifts for the benefit of the collective group. This is the concept of unity in diversity. The whole derives its substance from its individual parts. Therefore, the actions of the individual indirectly affect the whole.

We see this concept of covenantalism numerous times throughout Scripture. For example, in the Old Testament economy, the sin of Achan brought judgment upon the entire nation of Israel (Joshua 7), and the righteous act of Phineas brought God's blessings (Numbers 25). This principle did not pass away with the Old Testament economy, however. In I Corinthians 5, Paul exhorted the Corinthian church to "put away" from them the unrepentant adulterer with the following illustration:

Do you not know that a little leaven leavens the whole lump? Therefore purge out the old leaven, that you may be a new lump, since you truly are unleavened (verses 6b-7a).

The corrupting influence of sin should never be underestimated and God's judgment on an entire congregation is risked if one of its members is allowed to continue in open rebellion against His Word. This is why it is so important for the elders to protect the Church from moral and spiritual disintegration by removing the ungodly member via excommunication. Likewise, it is equally the responsibility of individual members of a church to disassociate themselves from an apostate church, so that they might not "partake of her sins" (Revelation 18:4).

Church incorporation flies in the very face of biblical covenantalism. This is seen primarily in the privilege of "limited liability," which means that the corporation cannot be held legally responsible for the actions of the individual members:

A corporation... should be distinguished from the individuals who compose it and those who control it as well as from the property which it owns. (32)

God certainly did not deal with the nation of Israel on the basis of limited liability, so why should modern churches seek this unbiblical status for themselves? Supposedly, limited liability protects the individual members from personal lawsuit. However, this is simply not the case. Franchises of a corporation are just as susceptible, if not more so, to a lawsuit than any other organization. Furthermore, the incorporated church itself greatly increases its own susceptibility to a lawsuit due to the fact that a business is far more likely to be sued than is a strictly religious organization.

Conclusion

It is time for the churches in America to wake up to the fact that they have seriously compromised the headship of Christ by incorporating. The very first sentence of the Bill of Rights states, "Congress shall make no law regarding an establishment of religion." No law means no law. Christian churches do not need to obtain a special "operating license" to avoid taxation; the federal government simply cannot tax them to begin with. The Church of Jesus Christ is forbidden by Scripture to merge with the State because the two exist as separate entities. The State is not to claim jurisdiction over the Church, and the Church is not to place herself in such a position. The Church does not need to request of the State permission to exist as a legal entity. Its charter is the Bible, and its article of incorporation are the commandments of God. As Jesus said, "No man may serve two masters" (Matthew 6:24). If this principle applies to an individual, how much more so to a church?

Church members should confront their pastors and elders on these issues. Do not let them simply brush you off with the claim that the subject has "been studied already," or that "we have always done it this way." Challenge them to produce a copy of the IRS statutes which state that a Christian church must incorporate as a 501(c)(3) organization in order to carry out its God-ordained functions. They will not be able to do this, because such a law simply does not exist.

The reaction to this article among incorporated churches will, in most cases, be denunciation. Unfortunately, this writer knows this from personal experience. It is far easier to sputter and threaten than it is to deal calmly and rationally with information that conflicts with the opinions and views which we have grown comfortable with. However, if your own church has incorporated and this is their response, do not accept the blusterings of the pastor and elders as a sufficient rebuttal of what has been presented here. Ask them to deal with specifics, not with vague generalities. Ask them to produce the actual legal documents which refute this position, not secondary sources which they have read. Be persistent and force these men to be honest with you and with themselves. You may find yourself unwelcome in your church, but at least you will have the satisfaction of having stood for the truth and for the sole prerogative of Christ to govern His own Church.

Endnotes

1. The American Heritage Dictionary (Houghton Mifflin Company,1985), p. 326.
2. Hale v. Henkel, 201 U.S. 43.
3. Black's Law Dictionary (West Publishing Company, 1991; Sixth Edition), p. 340.
4. Len Young Smith and G. Gale Roberson, Smith and Roberson's Business Law (West Publishing Company, 1966), p. 796.
5. Len Young Smith and G. Gale Roberson, ibid., p. 931.
6. Len Young Smith and G. Gale Roberson, ibid., p. 798.
7. Len Young Smith and G. Gale Roberson, ibid., p. 789.
8. U.S. Constitution, First Amendment.
9. Everson v. Board of Education, 1947.
10. Cf. Westminster Confession of Faith, Chapter XXIII:3.
11. 26 USC 508(c)(1)(A).
12. Tax Exempt Status for Your Organization, IRS Publication 557.
13. Ibid.
14. "Positive laws" are defined as "documents having general applicability and legal effect...." (44 USC 1505(a)). As such, they are applicable in "all the courts of the United States, the several states, and the territories and insular possessions of the United States" (1 USC 204(a)). For a law to be viewed as "positive law" it must declare itself to be such in its introduction (i.e. "This title has been made positive law by section 1 of act July 30, 1947...." 1 USC, General Provisions) and it must be entered in the Federal Register. It is interesting to note that the Internal Revenue Code does not declare itself to be positive law, nor has it ever been entered in the Federal Register. According to Michael L. White, Senior Counsel to the Director of the Office of the Federal Register:

Our records indicate that the Internal Revenue Service has not incorporated by reference in the Federal Register... a requirement to require income tax return (letter to Eddie Kahn, dated November 15, 1994).

This subject is outside the scope of this particular article. Suffice it to say, however, the Internal Revenue Code is a form of non-positive law, and therefore requires "voluntary compliance" before it can go into effect.
15. 26 USC 170(B).
16. 26 USC 501(c)(3).
17. Black's Law Dictionary, p. 588.
18. Amendment to the by-laws of a Reformed church in Denver,Colorado.
19. Reference: Leonard J. Coppes, article: "The Tax Status of Ministers," New Horizons, November 1995, p. 18.
20. 26 USC 3401(c). I have placed the word "mean" in brackets, not to change the meaning of the sentence, but to clarify it. In law, "include" most often is used as a term of limitation. In other words, if something is not included, it is excluded. The term "include" is used in this manner throughout the Internal Revenue Code to specify the limitations of the categories discussed.
21. 26 USC 872(a).
22. 26 USC 7701(a).
23. Black's Law Dictionary, p. 63.
24. Ibid., p. 339.
25. Stewart Machine Company v. Davis, 301 U.S. 548 (1937).
26. Len Young Smith and G. Gale Roberson, Smith and Roberson's Business Law, p. 786.
27. Len Young Smith and G. Gale Roberson, ibid., p. 787.
28. Hale v. Henkel, 201 U.S. 74-75.,
29. Roscoe Egger, quoted by Peter Kershaw, The Modern Church: Divine Institution or Counterfeit? (self-published, 1993), p. 8.
30. Black's Law Dictionary, p. 322.
31. Len Young Smith and G. Gale Roberson, Smith and Roberson's Business Law, p. 70.
32. Len Young Smith and G. Gale Roberson, ibid., p. 785.

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