Church of Scientology of California v. Internal Revenue Service
United States Supreme Court
484 U.S. 9 (1987)
- Written by Daniel Clark, JD
Facts
The Church of Scientology (church) (plaintiff) submitted requests to the Internal Revenue Service (IRS) (defendant) under the Freedom of Information Act (FOIA) for information concerning the church. The requests were broad, seeking, among other things, all documents, including internal IRS correspondence, containing the word scientology or referencing any of the religion’s major figures. Before the IRS produced anything under the request, the church sued the IRS in district court, seeking compelled release of a broad swath of documents. The district court reviewed the documents and held that they were protected from disclosure under § 6103 of the Internal Revenue Code (code), which contained an exception to FOIA for tax returns and tax-return information. On appeal, the circuit court, sua sponte, considered § 6103(b)(2) of the code, known as the Haskell amendment, which removed from the definition of returns and return information “data in a form which cannot be associated with, or otherwise identify . . . a particular taxpayer.” The circuit court affirmed the district court’s ruling and additionally held that the words “in a form” in § 6103(b)(2) narrowed the provision’s scope so as to reach only IRS reformulations of data, such as statistical studies or other composite products. The United States Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Rehnquist, C.J.)
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