An organization claiming to be a “church” exempt from federal income tax under section 501(c)(3) of the Tax Code is not entitled to a ruling that it is not a private foundation under section 509 when it has not filed an application for exemption for recognition of church status. The U.S. Court of Federal Claims has agreed with the Internal Revenue Service and dismissed the case. An organization called Alearis, Inc. was incorporated in the state of Delaware. Its sole member is “the Church” that was “founded at time immemorial when the Old Ones placed the Game into ecclesiastical trust for such purpose.” It claimed to be “organized exclusively for religious purposes to perform or carry out...