In a recent decision, the U.S. Court of Appeals for the Tenth Circuit reinforced the “plain meaning” approach to statutory interpretation in the case of God’s Storehouse Topeka Church v. United States, 2024 U.S. App. LEXIS 8478, 98 F.4th 990 (10th Cir. 2024). The court ruled that special audit procedures outlined in I.R.C. Section 7611, which are designed to protect churches’ First Amendment rights, do not limit the IRS’s authority to obtain records through third-party summonses during investigations involving churches. Emphasizing the unambiguous text of the statute, the Tenth Circuit declined to consider the statute’s purpose and legislative history, ultimately deciding in favor of the IRS.
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