The Ninth Circuit Court of Appeals has affirmed the imposition of federal income tax on a couple who set up their own church and took vows of poverty but totally controlled the church and used its income for their personal living expenses. Elizabeth and Fredric Gardner formed the Bethel Aram Ministries in 1993 as an “unincorporated ecclesiastical church ministry” but never filed an application for recognition as a church. In 1999, they signed vows of poverty and assigned all of their assets, including their home, to the organization. In 2001, they filed articles of incorporation in Nevada, naming Elizabeth Gardner as the “corporation sole,” a recognized form authorized in some states to...