The complaint challenges the church's tax-exempt status as a religious organization.

Lynn's letter to the IRS reads, in part: "The pastor's description of the candidates' stands and their personal religious beliefs was obviously aimed at encouraging congregants to cast ballots for Bush. The church is known for its stands on social issues and its opposition to legal abortion and gay rights. By lauding Bush's stands on these and other issues and attacking (Sen. John) Kerry's, Floyd was plainly telling his congregation to be sure to vote for Bush.

"I have enclosed a videotape that includes the entire sermon as well as a partial transcript. About 45 minutes into the message, Floyd begins to discuss the differences between Bush and Kerry. Please note that even the imagery employed by the church is designed to promote Bush. A huge photo of Bush is projected onto a screen that shows the president next to an American flag. By contrast, small photos of Kerry are used that show him as one person in a larger crowd. In addition, Bush is shown signing a ban on late-term abortions, an act most church members will laud, while Kerry is shown as one of a group of senators who opposed a law banning same-sex marriage, a stand most church members will likely oppose."

Organizations granted tax-free status under federal law "may not participate at all in campaign activity for or against political candidates," according to published IRS guidelines.

According to IRS regulations, tax-exempt organizations "are absolutely prohibited from directly or indirectly participating in, or intervening in, any political campaign on behalf of, or in opposition to, any candidate for elective public office. Contributions to political campaign funds or public statements of position, verbal or written, made on behalf of the organization in favor of or in opposition to any candidate for public office clearly violate the prohibition against political campaign activity. Violation of this prohibition may result in denial or revocation of tax-exempt status and the imposition of certain excise tax."

The guidelines add: "The political campaign activity prohibition is not intended to restrict free expression on political matters by leaders of organizations speaking for themselves, as individuals. Nor are leaders prohibited from speaking about important issues of public policy. However, for their organizations to remain tax-exempt under section 501(c)(3), leaders cannot make partisan comments in official organization publications or at official functions."

Churches may invite candidates to speak to the congregation during an election, as long as all candidates are afforded an equal opportunity to speak, according to the guidelines.