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To be tax-exempt under section 501(c)(3) of the Internal Revenue Code, an organization must be organized and operated exclusively for exempt purposes set forth in section 501(c)(3), and none of its earnings may inure to any private shareholder or individual.  We have learned that the burden of proving that a church meets the requirements of section 501(c)(3) falls upon the donor. Having to prove to the IRS that your church is compliant with the requirements of section 501(c)(3) is a heavy burden for anyone, especially when your church has opted not to file and does not have a 501(c)(3) approval letter. In this instance, if a donor is unable to prove that your church does indeed meet the requirements of section 501(c)(3), then the IRS will most likely determine that their donations to your church are not tax-deductible.