GOA: Last IRS 900-T Form & Group Tax Exempt Letter

As a follow-up, we thought you might like to see the 900-T form filed by the GOA in 2019.  I’m not understanding how the total payments to the archdiocese (line 52) in 2019 could be $10,000.  Maybe someone can explain it.  


Form filed in 2018 (same situation only the amount is just under $10,000): 131632516_201812_990T_2021043018045527

The Group Tax Exempt Letter

FinalLetter_13-1632516_GREEKORTHODOXARCHDIOCESEOFAMERICA_10132022_00 (1) 


  1. Wayne Matthew Syvinski says

    Who in blazes prepared this filing? Count Slopula?

    When I was a parish treasurer, I had to prepare this form. There was no way I would have sent such a disheveled filing to the IRS. BTW, I was asked by some parishioners why I was so prickly about details and procedures. My answer always was, “I don’t want to give the civil authorities any easy picks.”

    So, looking at this…filing…it shows a tax payment of $10,000 made at some unspecified time before the filing, but there is no *unrelated business income, which means the GOA was due the entire $10,000 back as a tax refund. My question: why did the GOA make a $10,000 estimated tax payment in the first place?

    The fact that the GOA might have unrelated business income isn’t necessarily unusual, but the fact that a round $10,000 was paid and then refunded in full looks really strange to me.

    *Unrelated business income (URI): in this context, it would mean income realized by the GOA unrelated to its religious mission. Pledge revenue would not be unrelated business income. Revenue realized because the GOA was also running, for example, a restaurant chain, would be URI.

    • Gail Sheppard says

      Thanks for the info. I had the same reaction. Someone even scribbled on the side of it. – It seems to me a form filled out like this would be a huge red flag. But maybe because it is a 501c3, the IRS won’t touch it.

      I don’t know if this is an issue, but if I were a parish, I could set up my own EIN and get my own tax break for being a 501c3. If I get a group tax exemption, a 501(c) status conferred by the IRS on a group of organizations instead of a single nonprofit, I would worry if my parish, for whatever reason, had to separate from the Archdiocese, the Archdiocese would get my property because they could claim I was part of a hierarchical church. I don’t know if this would be the case. Just speculating. I’d certainly want to get the question answered.

      Look at page 30 where the Greek Archdiocese stated their case in a similar matter, where it says, “Here, there is no question that the Episcopal Church met Jones’ instruction that a church could “ensure, if [it] so desire[s], that the faction loyal to the hierarchical church will retain the church property” if that intent was “embodied in some legally cognizable form.” – Would participation in a group tax exemption be a legally “recognizable form” of intent that the parish was a part of a hierarchical church (GOA) that would prevail in a property dispute?

      Maybe I’m misunderstanding what’s being said. https://www.supremecourt.gov/DocketPDF/20/20-534/161111/20201118143332016_20-534%20Amicus%20Brief.pdf

      Some experts weigh in and talk about this: “. . . the most important evidence concerning consent—the ordinary “civil legal documents” religious entities regularly use to “organize their affairs” and reflect their theological preferences. All Saints Parish Waccamaw v. Protestant Episcopal Church in the Diocese of S.C., 685 S.E.2d 163, 171 (S.C. 2009).

      Again, is a group tax exclusion a way to “organize their affairs” and reflect their theological preferences to be part of a hierarchical church that should get their property in a property dispute? https://www.supremecourt.gov/DocketPDF/20/20-261/156638/20201002133430883_Brief%20of%20Law%20and%20Religion%20and%20Constitutional%20Law%20Professors%20as%20Amici%20Curiae%20in%20Support%20of%20Petitioners%20.pdf

      This what must happen to be a subordinate and qualify for a group tax exclusion. Sure sounds like it defines the relationship and is a “way to organize their affairs.” A group exemption is simply 501(c) status* conferred by the IRS on a group of organizations, instead of a single nonprofit. This avoids the need for each entity to seek their own tax-exemption. In order for this to work, several circumstances must be present:

      – There must be a parent, or central, organization that will be considered the umbrella holder;
      – There must be 2 or more subordinate nonprofits that will make up the group members;
      – Each subordinate organization must be affiliated with the parent organization;
      – Each subordinate must be subject to the central organization’s general supervision or control;
      – Each subordinate must be exempt under the same paragraph of IRC (Internal Revenue Code) 501(c), though not necessarily the paragraph under which the central organization is exempt;
      – Each subordinate must be an independent entity with regard to corporate structure and governance, i.e., it is a separate legal entity with its own board of directors.

      Sure sounds like something a court could use to decide the entity is a subordinate of the archdiocese.

  2. Michael Bauman says
  3. If anyone reading this article is in the GOA you had better start fighting like hell against this.

    In citing the Episcopalians they have signaled what their plan is for the Archdiocese:

    1) Give all current Metropolitans the title of Bishop and make them subservient to the Metropolitan Archbishop with little to no autonomy in their dioceses. Do you really want to have Elpi breathing down your neck nonstop?
    **This is the way the Antiochian Archdiocese is set up BUT the two are not the same animal and the GOA will use their power for nefarious purposes**

    2) They are making dang sure that when they start going even more off the rails that parishes…and monasteries…are not able to leave the Archdiocese without being sued into oblivion over the property. Not only that but they are ensuring that if all the parishioners leave they will still be able to stuff their coffers by selling off property.
    For reference read about the Episcopalians and the breakaway diocese that created the Anglican Church in North America.

    3) If Metropolitans have no further autonomy over their diocese then the Metropolitan Archbishop will be able to bring the monasteries to heel. I’m sure that the ultimate goal to “integrate” the monasteries into the “life of the Archdiocese” or whatever they said.

    If there is a wolf in sheep’s clothing and you continue to believe it’s a sheep, then the only one you have to blame is yourself when you get bit.

    To anyone “in the know” who reads this who is in the GOA, the fact that Met. Emanuel is overseeing this should terrify you.

    Seems as though the next committee meeting is in March so I suggest you storm your parish priests and Metropolitans with concerns because everyone knows where this is headed.

    • Gail Sheppard says

      Exactly, Petros.

    • Well put, though I would hardly characterize American Episcopalians as “winners.” They are increasingly older, lonely, and isolated. Yes, they may be wealthy, but as the old adage says, that can’t buy you love, peace, or joy.

      How many American Episcopal churches date back hundreds of years – many have beautiful gothic architecture – yet they are physically and spiritually empty….. Yes, many of these parishes have large endowments, but these old gothic structures are expensive as heck to upkeep, so I imagine much of their endowment funds go toward building upkeep.
      Spiritually, no one goes there anymore.

      The average age of the ECUSA parishioner is about 72 years old — most of these probably are folks who’ve been Episcopalian all their lives and have no intent on changing, yet their kids don’t go and evangelism is nonexistent. The ECUSA’s method of evangelism is to try to be cool and trendy, embracing any latest fad that it finds, embracing LGBTQism, but — to the shock of no one — this doesn’t attract those who are truly hungry for God… most would rather have coffee with friends on a Sunday morning than attend a spiritually bankrupt ECUSA service. Just sayin’….

      I’m not a big fan of the ACNA, but it is probably spiritually far “fuller” than any wealthy, empty ECUSA building. I have a few friends in the ACNA, and they have an “academic respect” (as I put it) for Orthodox Christianity, but as they’ve said, it’s simply too weird for them as Americans to get into. I get it…. this is a super hard hurdle for so many. Having been Orthodox from my youth, my experience is so different. Having lived as an Orthodox Christian in a Western land for so long, you get a feel for how different are the eastern and western Christian perspectives on life and on what the Church is.

      As it was put once, the ACNA is for those disaffected Episcopalians who “like what the Orthodox believe but now how we look.” Pretty much sums it up. Highly recommend listening to Metropolitan Jonah’s 2009 or 2010 address to the ACNA conference when he was OCA Metropolitan — it’s still on YouTube. Eye opening.

      I don’t see the ACNA as attracting a large convert movement. There’s no depth there, there’s no mysticism there either…. authentic Christianity accurately embraces the Holy Mysticism of God, that “inexpressible wonder” as we sing in one of the Holy Friday odes… that “I know and feel God is here but I can’t put it into words.” Orthodox Christianity understands and honors God’s energies; our inexpressible lived experience matters.
      Western Christianity is simply not good at doing this.

      The institutional ECUSA may be wealthy and may have “gotten all the buildings,” but let’s not waste time being envious of them. In the end, we probably should have compassion on them, alone, deluded, and lost as they are. May God draw each of those stuck in the ECUSA to His One, Holy, Catholic, and Apostolic Church, in faith and in love.


    Check this out…only two distinct hierarchical sites listed: NY and PGH…and only two churches in IL included…coincidence maybe/not?

    Several years ago, a suggestion was made to my parish leader (also archon 100 type) to place all holdings, real and financial, in trust for the church. You know, the met of Chicago model. To protect our assets from this type of money grubbing. Didn’t happen. So now who’s going to man the kalamari fryer…

    • Gail Sheppard says

      It’s important to be proactive when it comes to this group.

    • I watched the movie “Man of God,” about St. Nektarios, that came out last year…remarkable how it showed him putting his convent’s assets in a trust to give the nuns some protection from the whims of the Church of Greece bishops. I don’t know enough about St. Nektarios to verify the historical accuracy of that part of the film, but it was very striking to see such piercing shrewdness on the part of a Saint AND to see it portrayed in a film that has been reaching a sizable audience.

    • LOL Ella!

  5. This official notice of “thoughtful changes”
    Still can’t figure out how a rudderless chartless group can impose this on anyone…


  6. Mark Carmitchell says

    In the 1980s the GOA tried to specify accounting standards for parish PCs and so contact the three major fund accounting software providers so they may provide GOARCH versions of their software so any data parishes sent to the GOARCH would be in compatible format. You would not imagine the uproar: from “Why can’t you just use SORT/MERGE?” “We don’t use fund accounting?” “Are these firms giving you kickbacks?” The result was a dissolution of the committee and dumping the project on a hapless kid just out of college, who went on to being suckered for even bigger things and is currently in the news.