Memo to all 501(c)(3)s (especially churches)... yes, the head of your organization can endorse a candidate. Just be sure to not use the organization letterhead when you do it... it matters (apparently) to the IRS.
As I write this, I'm thinking about the paradox in IRS rules at times... in what I like to call the "hang a lantern on your problem" rule, the IRS has no problem when an endorsing person is listed with their organizational affiliation along with an asterisk that leads the reader to a disclaimer stating "organizational affiliation listed for identification purposes only." (IRS FS-2006-17) Contrast that with this instance where clear organizational identification (the letterhead) seems to be leading this church into an investigation even though the pastor is suggesting that the letter underscored a personal endorsement. I think you can distinguish the two endorsement scenarios, but it underscores a continuing problem for all 501(c)(3)s out there: the facts and circumstances analysis is so subjective that it's sometimes difficult to know where the line is between legal and illegal activity.
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