Church of Scientology v. Irs, 484 U.S. 9 (1987)

Church of Scientology of California v. Internal Revenue Service

No. 86-472

Argued October 5, 1987
Decided November 10, 1987
484 U.S. 9

CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR

THE DISTRICT OF COLUMBIA CIRCUIT

Syllabus

Section 6103(a) of the Internal Revenue Code provides that tax returns and "return information" shall be confidential and shall not be disclosed except as authorized. "Return information" is defined in § 6103(b)(2) to include a taxpayer’s identity, the nature, source, or amount of his income, payments, receipts, deductions, exemptions, credits, assets, liabilities, net worth, tax liability, tax withheld, deficiencies, overassessments, tax payments, or any other data with respect to a return or to the determination of the existence or amount of liability. However, § 6103(b)(2) also contains the proviso, known as the Haskell Amendment, that "return information" does not include data "in a form" which cannot be associated with, or otherwise identify, directly or indirectly, a particular taxpayer. Upon the Internal Revenue Service’s slow response to petitioner’s Freedom of Information Act (FOIA) request for the production of numerous records containing information relating to it, petitioner filed suit in Federal District Court to compel release of the materials. The court held that the IRS had correctly limited its search for and disclosure of the requested materials, and the Court of Appeals affirmed, holding that the Haskell Amendment’s "in a form" phrase contemplates agency reformulation of return information into a statistical study or some other composite product and not merely the deletion of the taxpayer’s name and other identifying data.

Held: The Haskell Amendment does not exempt from § 6103(b)(2)’s definition of confidential "return information" material in IRS files which can be redacted to delete those parts which would identify a particular taxpayer. If the mere removal of identifying details sufficed to put the information "in a form" envisioned by the Amendment, the remainder of the protected categories of information included in § 6103(b)(2) would often be irrelevant, and the "in a form" phrase would itself be extremely awkward, confusing, and unnecessary. Petitioner’s contrary construction of the Amendment is likewise belied by other provisions of § 6103 which set forth various exceptions to the general rule of confidentiality and recognize that "return information" remains such even when it does not identify a particular taxpayer. Moreover, the legislative history also refutes petitioner’s construction, since allowing the disclosure of otherwise confidential return information merely by the redaction of identifying details would undercut § 6103’s primary purpose of limiting access to tax filings. In fact, the Amendment was simply intended to permit continuation of the IRS’ practice of releasing statistical studies and compilations that do not identify particular taxpayers. Thus, since deletion of identifying data would not make otherwise protected return information discloseable, there is no merit to petitioner’s contention that respondent has an FOIA duty to undertake such redaction. Pp. 14-18.

253 U.S.App.D.C. 85, 792 F.2d 153, affirmed.

REHNQUIST, C.J., delivered the opinion of the Court, in which all other Members joined, except BRENNAN and SCALIA, JJ., who took no part in the consideration or decision of the case.