Church of Scientology of California v. Internal Revenue Service

PETITIONER: Church of Scientology of California
RESPONDENT: Internal Revenue Service
LOCATION: Hoopa Valley Indian Reservation

DOCKET NO.: 86-472
DECIDED BY: Rehnquist Court (1987-1988)
LOWER COURT: United States Court of Appeals for the District of Columbia Circuit

CITATION: 484 US 9 (1987)
ARGUED: Oct 05, 1987
DECIDED: Nov 10, 1987

ADVOCATES:
Albert G. Lauber, Jr. - on behalf of the Respondent
Alfred Wong -
Michael Lee Hertzberg - on behalf of the Petitioner

Facts of the case

Question

Media for Church of Scientology of California v. Internal Revenue Service

Audio Transcription for Oral Argument - October 05, 1987 in Church of Scientology of California v. Internal Revenue Service

Audio Transcription for Opinion Announcement - November 10, 1987 in Church of Scientology of California v. Internal Revenue Service

William H. Rehnquist:

I have the opinion of the Court to announce in No. 86-472, the Church of Scientology of California versus the Internal Revenue Service.

Section 6103 of the Internal Revenue Code lays down a general rule that returns and return information shall be confidential.

This confidentiality of return information is modified by the so-called "Haskell Amendment", which provides that such term does not include data in a form which cannot be associated with or otherwise identified directly or indirectly a particular taxpayer.

Petitioner, the Church of Scientology is requested under the Freedom of Information Act data from the IRS and it argued that the Haskell Amendment removed from the confidentiality protection of 6103 all return information that does not by identify a particular taxpayer.

It also believes that the IRS has an obligation to delete identification from all return information and disclose the information when requested to do so under FOIA.

We disagree and hold that the mere deletion of identifiers from otherwise protected return information does not deprive of its confidential nature.

Neither the language nor the legislative history of Section 6103 suggests this intent.

Since such deletion will not make protected information disclosable, we hold the IRS has no duty under the Freedom of Information Act undertake such redaction.

We therefore affirm the judgment of the Court of Appeals which held the same way.

Justice Brennan and Justice Scalia took no part in the consideration or decision of this case.