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Leading Stradley Ronon Nonprofit & Religious Attorneys File Comments in Response to the IRS Proposed Revenue Procedure as Part of Pro Bono Representation

August 18, 2020
Firm News

WASHINGTON, DC – Stradley Ronon is pleased to announce attorneys Mark E. Chopko and Jennifer A. Gniady filed comments with the IRS on behalf of five national religious denominations concerning the proposed revenue procedure (Notice 2020-36) for the group ruling tax exemption program. The denominations are Evangelical Lutheran Church in America, the General Synod of the United Church of Christ, General Council on Finance and Administration of The United Methodist Church, the Protestant Episcopal Church in the United States of America (also known as The Episcopal Church), and the General Synod of the Reformed Church in America.

The IRS proposal would impose stringent definitions of “supervision” and “control,” among other changes, that would revoke the traditional accommodation for religious organizations under IRS practice. Chopko and Gniady submitted comments objecting that the proposed revenue procedure could not be implemented by these religious bodies consistent with their theology. If implemented, it would undermine the group exemption process not only for these religious bodies but also for the IRS that would then be saddled with serial applications from literally tens of thousands of exempt entities. The proposal, if implemented, would also violate rights protected under the Religious Freedom Restoration Act and the First Amendment.

Chopko chairs Stradley Ronon’s nonprofit and religious organizations practice group and advises clients, including colleges and universities, in matters involving structural, business, governance, regulatory and complex litigation. He specializes in defending religious organizations and teaches a seminar on church-state law at Georgetown University Law Center and is an adjunct in the School of Foreign Service. A former general counsel for the U.S. Conference on Catholic Bishops, he has participated in more than 30 Supreme Court cases as counsel for religious groups in friend-of-the-Court briefs.

Gniady helps nonprofit organizations of all sizes navigate complex legal issues while remaining true to their charitable missions. Her practice combines experience with both tax exemption issues and corporate matters. She works with clients to respond to existing threats and legal issues, while counseling practices to strengthen the organization in the long term. Her clients include charities, religious organizations, associations, schools and arts organizations. Her practice includes forming nonprofit organizations, advising on corporate governance and bylaws, analyzing lobbying and fundraising practices, responding to inquiries from IRS, state, and local charitable regulators and managing litigation.

About Stradley Ronon
Counseling clients since 1926, Stradley Ronon has helped private and public companies – from small businesses to Fortune 500 corporations – achieve their goals by providing pragmatic, value-driven legal counsel. With offices in eight strategic locations, our responsive team of more than 200 attorneys seamlessly addresses the full spectrum of our clients’ needs, ranging from sophisticated corporate transactions to complex commercial litigation.

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