Washington and Lee Law Review Volume 44 | Issue 1 Article 4 Winter 1-1-1987 But Reverend, Why Does Your Baptismal Font Have A Diving Board? Equitable Treatment For Vows Of Poverty Under The edeF ral Income Tax J. Timothy Philipps Follow this and additional works at: https://scholarlycommons.law.wlu.edu/wlulr Part of the Religion Law Commons, and the Taxation-Federal Commons Recommended Citation J. Timothy Philipps, But Reverend, Why Does Your Baptismal Font Have A Diving Board? Equitable Treatment For Vows Of Poverty Under The Federal Income Tax , 44 Wash. & Lee L. Rev. 19 (1987), https://scholarlycommons.law.wlu.edu/wlulr/vol44/iss1/4 This Article is brought to you for free and open access by the Washington and Lee Law Review at Washington & Lee University School of Law Scholarly Commons. It has been accepted for inclusion in Washington and Lee Law Review by an authorized editor of Washington & Lee University School of Law Scholarly Commons. For more information, please contact
[email protected]. BUT REVEREND, WHY DOES YOUR BAPTISMAL FONT HAVE A DIVING BOARD? EQUITABLE TREATMENT FOR VOWS OF POVERTY UNDER THE FEDERAL INCOME TAX J. TimOTHY PHIUnPps* I. INTRODUCTION In 1977 the Internal Revenue Service (IRS or Service) issued a revenue ruling' that drastically changed its position concerning the imposition of federal income tax on members of traditional bona fide religious orders who have taken a vow of poverty. Under these vows a member of the order renounces all wealth and promises to give any income to the religious order. The position taken in the ruling (and maintained by the IRS in subsequent litigation) is essentially two-fold.