In the United States v. Christian Echoes National Ministry, Inc., 1971 case, the Supreme Court upheld a decision by lower courts that revoked the tax-exempt status of Christian Echoes National Ministry (CENM). The Internal Revenue Service (IRS) had determined that CENM was not entitled to this status due to its substantial involvement in influencing legislation and participating in political campaigns on behalf of individual candidates. This violated IRS rules for non-profit organizations which state they must refrain from such activities to maintain their tax-exempt status. CENM challenged this decision arguing it infringed upon their First Amendment rights; however, both lower courts and ultimately the Supreme Court disagreed with them. They ruled that while these entities have a right to free speech, they do not have an inherent right to subsidized public financing via tax exemption if they engage in certain prohibited political activities.

In the dissenting opinion for United States v. Christian Echoes National Ministry, Inc., Justice Harlan disagreed with the majority's decision to revoke tax-exempt status from a religious organization due to its political activities. He argued that this ruling violated First Amendment rights of free speech and religion by imposing an undue burden on religious organizations who wished to engage in public discourse about important issues. Furthermore, he contended that it was not within the IRS’s jurisdiction or expertise to determine what constitutes excessive lobbying or political activity for a church group. This could potentially lead to arbitrary and inconsistent enforcement of these rules across different organizations. Lastly, he expressed concern over potential government intrusion into religious affairs through such regulation.