Tax Exemption

The Symbol of Ra

The IRS Revenue Ruling

79-359, 1979-2 C.B. 226 specifies that a qualifying organization whose purpose is to provide burial services that directly support and maintain basic tenets of a religion is operated exclusively for charitable purposes and is exempt from tax under section 501(c)(3) of the Code. In addition, the ruling recognizes that such organizations may receive fees in order to provide the burial services. Summum's rites of Mummification and Transference fall under this IRS rule.

In a letter to Summum dated May 28, 1986, the Internal Revenue Service specifically ruled that conducting and facilitating Mummification and Transference in accordance with Summum's religious precepts does not change Summum's federal tax exempt status.

Excerpts from the IRS letter to Summum

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As a precept of your religion, you practice the rites of Mummification and Transference...

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Revenue Ruling 79-359, 1979-2 C.B. 226, provides that an organization whose purpose is to provide burial services consistent with the basic tenets of a religious,[sic] is operated exclusively for charitable purposes with the meaning of section 501(c)(3) of the Code.

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Accordingly, based on the information submitted, we rule that conducting and/or facilitating the rites of Mummification and Transference will not jeopardize your current status as an organization described in section 501(c)(3) and 170(b)(1)(A)(i) of the Internal Revenue Code...

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