Church of Scientology v. Internal Revenue Service
Headline: Court limits FOIA access to IRS files, rules that simply deleting names does not allow release of tax return-related material, leaving a religious group's request blocked and upholding IRS confidentiality.
Holding:
- Stops FOIA requesters from forcing the IRS to remove identifiers and disclose tax data.
- Protects taxpayers’ audit reports and IRS internal notes from disclosure after simple redaction.
- Means researchers may still receive only statistical compilations, not redacted individual return documents.
Summary
Background
A religious organization asked the IRS for many internal records under the Freedom of Information Act, seeking documents that mentioned the group, its leaders, or related entities. The IRS refused to release many items, saying they were protected as tax “returns” or “return information” under section 6103 of the Internal Revenue Code. The organization sued to force disclosure; the District Court sided with the IRS, and the Court of Appeals later reviewed the meaning of a 1976 change called the Haskell Amendment.
Reasoning
The central question was whether the Haskell Amendment removes confidentiality from IRS materials simply because identifying details can be deleted. The Court read the amendment as referring to statistical compilations or other data already in a form that cannot be tied to an individual taxpayer—not as a command that the IRS must strip identifiers from existing files. The opinion relies on the detailed statutory definition of return information and the legislative history showing Congress meant to preserve tighter restrictions on tax data, allowing disclosure of statistical studies but not forcing disclosure of redacted documents.
Real world impact
The Court affirmed the lower court and held that removing names or other identifiers from protected tax materials does not convert them into nonconfidential records. Practically, FOIA requesters cannot compel the IRS to redact and release documents that qualify as return information; only nonidentifying statistical compilations are clearly subject to disclosure. This decision resolves conflicting lower-court views and leaves the IRS’s confidentiality rules intact for most internal tax records.
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