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What "constitutes a church"? The First Amendment to the Costitution, of course. It states "Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof". Since Congress created the position of commissioner of Internal Revenue, the IRS has no jurisdiction over churches. Congress, nor any commission formed by Congress, has no business attempting to determine whether or not the definition of a church is a place, an organization, or even a person.