How to Report a Church to the IRS: Form 13909

To report a church to the IRS, fill out Form 13909, the Tax-Exempt Organization Complaint (Referral), and send it with your supporting evidence to the IRS office in Dallas that screens exempt-organization referrals. You can mail it or email it, and you can file anonymously. The strength of the complaint comes almost entirely from what you put in the narrative and what you attach to back it up. Because churches receive automatic tax-exempt status without applying, the IRS depends on outside reports to catch problems.¹

What the IRS Will Actually Investigate

Not every questionable decision by church leadership is a federal tax matter. The IRS is looking for conduct that threatens the organization’s qualification under Section 501(c)(3). A complaint that fits one of the categories below has a real chance of being screened for action. One that doesn’t will be set aside.

Money Flowing to Insiders

The most common reportable problem is private inurement: church funds benefiting insiders personally rather than the religious or charitable mission. That looks like inflated pastor or board salaries, personal use of church-owned property, church money paying private debts, or sweetheart real estate deals between the church and its leaders. No part of a 501(c)(3) organization’s earnings can benefit any private individual with influence over it.² The Code also imposes excise taxes on the insider who receives an excess benefit and on managers who knowingly approve it.³

Campaigning for Candidates

Churches are absolutely prohibited from participating or intervening in any political campaign for or against a candidate for public office. Endorsing candidates from the pulpit, donating church funds to a campaign, distributing campaign materials, and hosting events designed to boost a particular candidate all qualify.² Nonpartisan voter education, voter registration drives, and candidate forums open to all sides are permissible; the line is favoring one candidate or party over another. Recordings, bulletins, social posts, and written communications showing the church taking sides in a specific race are the evidence that carries this kind of complaint.

Substantial Lobbying

Churches can speak on moral and social issues, but they cannot devote a substantial part of their activities to influencing legislation. Organized letter-writing campaigns aimed at legislators, significant lobbying spending, and staff time dedicated to pushing specific bills are the things to document. The IRS does not set a bright-line percentage for churches on this, so a report needs concrete evidence of how much time and money go toward legislative advocacy.²

Unreported Commercial Income

A church that regularly earns income from activities unrelated to its religious mission owes tax on that income. A commercial bookstore open to the public, a paid parking lot, or event-space rental run as a regular business can all generate unrelated business income. When gross income from these activities reaches $1,000 or more, the church has to file Form 990-T and pay tax on it.⁴ A church pulling substantial commercial revenue and never filing is worth reporting.

Illegal Activity or Public-Policy Violations

An organization operating for illegal purposes, or in ways that violate fundamental public policy, loses the basis for tax-exempt treatment. If a church’s real activities have shifted away from religious or charitable purposes toward serving its leaders’ financial interests, the IRS has grounds to revoke exemption entirely.

What to Gather Before You File

A vague complaint goes nowhere. The IRS looks for patterns backed by specifics.

At minimum, you need the church’s legal name and physical address. Include its Employer Identification Number if you can find one. Churches are not required to file annual Form 990 returns, so their EIN may not appear in the usual public databases.¹ The IRS Tax Exempt Organization Search tool covers organizations that have received determination letters or appear on other IRS lists.⁵ A Form 990-T filed for unrelated business income is publicly available for three years after the filing deadline.⁶ Can’t find an EIN? Submit anyway with whatever identifying details you have.

The narrative section is where complaints succeed or fail. Include specific dates, names, dollar amounts where you know them, and a clear account of what happened. Attach whatever you can: sermon recordings, bulletins endorsing a candidate, internal financial documents, emails, social media screenshots, meeting minutes. Screening agents are working through many referrals and will prioritize the ones that give them something concrete to pull on.

Submitting Form 13909

Form 13909 is a PDF you download from the IRS website, complete, and send in. The IRS will also accept a plain letter with attachments, but using the form makes sure you cover what the screening agents look for.⁷

Send the completed form and attachments to one of two places:

By mail: IRS TEGE Classification, Mail Code 4910DAL, 1100 Commerce Street, Dallas, TX 75242-1027
By email: eoclass@irs.gov, with your documents saved as PDFs and a subject line that includes the church’s name⁸

Send one complete complaint. Duplicates slow processing rather than boosting priority.

You can file anonymously. The form has a checkbox for withholding your identity, and you can enter “Anonymous” for your name. The trade-off is that the IRS cannot come back to you with follow-up questions, and you won’t get the acknowledgment letter that identified complainants receive.⁸ If your evidence is thorough, anonymity shouldn’t weaken the referral. If it’s thin, losing the ability to clarify might.

After You File

You will hear almost nothing back. Federal confidentiality rules bar the IRS from telling you whether an investigation was opened, what it found, or what action followed. That applies to every tax investigation, not just church complaints.⁹ If you gave your name and address, you’ll get a letter acknowledging receipt of your referral. It will not tell you anything else. Anonymous filers don’t get even that.⁷

Expect any action to move slowly. Federal law imposes procedural hurdles on church investigations that don’t apply to other nonprofits. A church tax inquiry can begin only after a senior Treasury official personally reviews the facts and puts in writing a reasonable belief that the church doesn’t qualify for exemption or is engaged in taxable activity. A line-level agent cannot start the process alone.¹⁰ The IRS must send written notice of the concerns, wait at least 15 days, send a second notice describing the specific records it wants, and wait another 15 days before examining anything. A minimum of 30 days passes between first notice and any record review, and the church gets a conference opportunity at each stage.¹¹

You can, however, check for yourself whether a church’s exempt status has been revoked. The IRS Tax Exempt Organization Search tool includes an automatic revocation list, searchable by name or EIN. A listing there doesn’t always reflect current status; the organization may have been reinstated, which shows up as a new determination letter with an effective date on or after the revocation.⁵ For a church that was never formally recognized in the first place, since exemption is automatic, a revocation may not appear in any public database at all. The only public sign of enforcement in that case might be a court filing if the matter is litigated.

If You Want a Financial Reward

Form 13909 reports a violation. It does not make you eligible for a whistleblower award. That requires a separate filing: Form 211, Application for Award for Original Information, submitted to the IRS Whistleblower Office.¹²

When the tax, penalties, and interest in dispute exceed $2 million and the IRS collects based on your information, the award is mandatory at 15 to 30 percent of collected proceeds, depending on how substantially your information contributed.¹³ Below that $2 million threshold, which covers most church cases, awards follow the same percentage framework but are discretionary rather than guaranteed.¹⁴

To qualify, you have to provide specific, timely, and credible information; sign under penalty of perjury; and give your contact details. Anonymous whistleblower claims are not eligible for awards. Current and former Treasury Department employees are disqualified, along with federal employees who got the information through their official duties.¹²

Federal law also protects whistleblower employees from retaliation. An employer that fires, demotes, suspends, or harasses an employee for reporting tax violations can be challenged through a complaint to the Secretary of Labor or a lawsuit in federal district court.¹⁵ That protection is tied to the employment relationship. A congregation member who isn’t employed by the church would have to rely on general legal remedies for any retaliatory conduct.

1
Internal Revenue Service. Churches, Integrated Auxiliaries and Conventions or Associations of Churches
2
Office of the Law Revision Counsel. 26 USC 501 – Exemption From Tax on Corporations, Certain Trusts, Etc.
3
Office of the Law Revision Counsel. 26 USC 4958 – Taxes on Excess Benefit Transactions
4
Internal Revenue Service. 2025 Instructions for Form 990-T
5
Internal Revenue Service. Search for Tax Exempt Organizations
6
Internal Revenue Service. Public Inspection and Disclosure of Form 990-T
7
Internal Revenue Service. IRS Complaint Process – Tax-Exempt Organizations
8
Internal Revenue Service. Form 13909, Tax-Exempt Organization Complaint (Referral)
9
Office of the Law Revision Counsel. 26 USC 6103 – Confidentiality and Disclosure of Returns and Return Information
10
Office of the Law Revision Counsel. 26 USC 7611 – Restrictions on Church Tax Inquiries and Examinations
11
eCFR. 26 CFR 301.7611-1 – Questions and Answers Relating to Church Tax Inquiries and Examinations
12
Internal Revenue Service. Submit a Whistleblower Claim for Award
13
Internal Revenue Service. Whistleblower Office at a Glance
14
Internal Revenue Service. 25.2.2 Whistleblower Awards
15
Office of the Law Revision Counsel. 26 USC 7623 – Expenses of Detection of Underpayments and Fraud, Etc.