The Washington Post reported that the Bush-Cheney campaign has circulated guidelines that are designed to mobilize Bush’s religious base.

The instruction sheet circulated by the Bush-Cheney campaign to religious volunteers lists 22 “duties” to be performed by specific dates. By July 31, for example, volunteers are to “send your Church Directory to your State Bush-Cheney ‘04 Headquarters or give [it] to a BC04 Field Rep” and “Talk to your Pastor about holding a Citizenship Sunday and Voter Registration Drive.”

By Aug. 15, they are to “talk to your Church’s seniors or 20-30 something group about Bush/Cheney ‘04” and “recruit 5 more people in your church to volunteer for the Bush Cheney campaign.”

By Sept. 17, they are to host at least two campaign-related potluck dinners with church members, and in October they are to “finish calling all Pro-Bush members of your church,” “finish distributing Voter Guides in your church” and place notices on church bulletin boards or in Sunday programs “about all Christian citizens needing to vote.”

Although Tax Experts, unnamed in the article, say that the campaign is walking a fine line between permissible and un-permissible activity, Republican campaign officials claim that the guidelines are within the law.  An IRS spokesman, responding to The Washington Post, said—“It would be inappropriate for the IRS, based on a limited set of facts and circumstances, to render a judgment about whether the activities in this document would or would not endanger a church’s tax-exempt status.”

For more on legality, and for reaction by some religious organizations

It seems to me that field volunteers for BC04 could privately recruit additional campaign workers from their church memberships, ask their pastors to hold registration drives, and could even turn over a personal copies of Church Directories*. However, partisan activity by a Pastor during an official Church function would be a violation of tax law.

According to some guidelines provided by the Americans United for Separation of Church and State.

Churches and other non-profit organizations that hold 501(c)(3) tax-exempt status must abide by Internal Revenue Service regulations barring any involvement in partisan politics. The blanket prohibition concerns only races for public office, not issues. Religious leaders may speak out from the pulpit or in other forums on moral and political issues. However, churches and pastors may not endorse candidates for public office or advise congregants to vote for or against certain candidates. Federal tax law in this area is quite strict, and the IRS has indicated that it follows a “zero tolerance” policy toward violations.

Americans United (AU) further advises churches to be wary about passing out voters guides prepared by outside organizations. Since these organizations operate under a different part of the tax code, they can participate in some activities not allowed to churches. AU further cautions that Federal Courts have not cleared the Christian Coalition’s voter guides for distribution in houses of worship.

The rules are a bit more complex than interpretation provided by the AU. The IRS cautions that even their own guidelines are not comprehensive.

For one example of complexity, consider voting guides. They are permitted but they must meet certain criteria:

■ whether the candidates’ positions are compared to the organization’s position,
■ whether the guide includes a broad range of issues that the candidates would address if elected to the office sought,
■ whether the description of issues is neutral,
■ whether all candidates for an office are included, and
■ whether the descriptions of candidates’ positions are either:
- -the candidates’ own words in response to questions, or
- -a neutral, unbiased and complete compilation of all candidates’ positions.

I imagine that the BC Campaign would be walking a very fine line in providing neutral descriptions of issues and a neutral and complete compilation of other candidates positions. As would any campaign group for that matter.

The IRS routinely sends routinely sends out their guidelines to charitable organizations, educational organizations and Churches in election years. This year they also sent out a letter to the seven political parties to remind them that political activity by a Church or charitable organization could cause that organization to lose their tax-exempt status. AU believes this to be the first time that the IRS issued such a letter.

Some Churchgoers didn’t take kindly to the direction. This AP article on Yahoo News lists several religious leaders that spoke out against the campaign initiative. However, the lead discussed the Southern Baptist convention which has strongly supported Bush in the past.

The Southern Baptist Convention, a conservative denomination closely aligned with President Bush, said it was offended by the Bush-Cheney campaign’s effort to use church rosters for campaign purposes.

“I’m appalled that the Bush-Cheney campaign would intrude on a local congregation in this way,” said Richard Land, president of the Southern Baptist Convention’s Ethics & Religious Liberty Commission.

“The bottom line is, when a church does it, it’s nonpartisan and appropriate. When a campaign does it, it’s partisan and inappropriate,” he said. “I suspect that this will rub a lot of pastors’ fur the wrong way.”

It is probably too much to hope that fence mending on this issue will be a distraction to the BC04 campaign.

* Mr. Land disagrees with me.