The Internal Revenue Service has told an organization that says it operates “for the advancement of Christianity and for other charitable purposes” that it does not qualify for a federal tax exemption as a church under Section 501(c)(3) of the U.S. tax code.

In its application for tax-exempt status, the organization said it conducts some “street ministry” activities, expects to rent a building and buy equipment to hold indoor services, and might one day start a religious school to educate young people.

The group said its board of directors has four members: its pastor, who is the founder and board chairman; his wife, who is the co-chair, secretary, and treasurer; a son, who is assistant secretary; and another son.

In its ruling, the IRS noted that no definition of “church” appears in the Internal Revenue Code.

However, the tax agency and federal courts have identified several factors that the government can use to decide whether an organization is a church for tax purposes.

Among them, the IRS said: the presence of an established congregation served by an ordained ministry; the provision of regular religious services and religious education for young people; and the “dissemination of a doctrinal code.”

“While the fact that an organization has a small congregation does not disqualify it from being considered a church,” the IRS said, “if such an organization is not actively engaged in trying to acquire new members, it will not qualify for exemption.”

But the revenue service said the group applying for a tax exemption in this case lacks “all of the significant elements” used to determine that an organization qualifies as a church.

The group did not provide the government with details about its street ministry, its current or future finances, or how it planned to communicate its presence to others as a way to recruit members, the IRS said.

“You do not have a group of people who come together on a regular basis and you do not hold regular religious services,” the tax agency said. “Your organization consists only of four members of a single family and you do not even hold regular services for those individuals. Furthermore, you have provided no evidence that you are actively seeking new members.”

The IRS continued: “You do not have an established place of worship, you do not have a membership distinct from another church or denomination, and you do not maintain schools or education activities either for the young or to prepare ministers.”

Thus, the tax agency concluded, the organization is not operating as a church or as any kind of charity.

In addition, the IRS said the group failed to prove that the people involved would not gain improper benefits from their relationship to the organization. “The structure of your organization indicates that it can be used to benefit private individuals,” it said, “and you lack safeguards that would help to prevent such use.”

As is its policy, the IRS did not identify the organization or people involved in its ruling.