## Facts

- The Church of Scientology of California submitted a Freedom of Information Act (FOIA) request seeking numerous IRS records relating to the Church.
- The IRS withheld certain requested materials, asserting they were confidential “return information” protected from disclosure by 26 U.S.C. § 6103.
- The Church sued in federal district court to compel disclosure.
- The district court upheld the IRS’s limited search and nondisclosure based largely on § 6103.
- The D.C. Circuit affirmed, construing the “Haskell Amendment” in § 6103(b)(2) as allowing disclosure only when data is converted into a statistical or composite form, not when identifiers are merely deleted.
- The Supreme Court granted certiorari.

## Issues

1. Whether the Haskell Amendment to 26 U.S.C. § 6103(b)(2) excludes from “return information” IRS file materials that could be disclosed if taxpayer-identifying details are redacted.
2. Whether FOIA can compel disclosure of information that § 6103 makes confidential (via FOIA Exemption 3).

## Decision

- The Supreme Court unanimously affirmed.
- The Court held that the Haskell Amendment does not remove IRS materials from the definition of confidential “return information” merely because identifying details can be deleted.
- Because § 6103 bars disclosure of covered return information, FOIA cannot be used to obtain it.

## Legal Principles

- 26 U.S.C. § 6103 establishes a broad rule that “returns and return information” are confidential unless a specific statutory authorization permits disclosure.
- The Haskell Amendment excludes from “return information” only data “in a form” that cannot identify a taxpayer; it does not require disclosure of underlying return information simply through redaction of names or similar identifiers.
- Interpreting the Haskell Amendment to allow routine redaction would undermine § 6103(b)(2)’s detailed, categorical protection of tax-related information and conflict with § 6103’s overall structure and confidentiality purpose.
- Section 6103 functions as a FOIA Exemption 3 nondisclosure statute; when § 6103 prohibits disclosure, FOIA does not override that prohibition.

## Conclusion

The Court held that tax “return information” remains protected by § 6103 even if identifying details could be removed, and therefore FOIA cannot compel release of such IRS materials absent a statutory authorization for disclosure.


Church of Scientology of Cal. v. I.R.S., 484 U.S. 9 (1987)