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The Church of Scientology has long been a vocal critic of government abuses, and some IRS officials saw the law as an obstacle to their habitual circumvention of constitutional safeguards. The IRS commissioner from 1981 to 1986 called the law’s regulations “little more than a series of mechanistic tests and hoops for the Service to jump through.”

The Church of Scientology established the first major court precedent strengthening the Church Audit Procedures Act in 1990 when the US District Court in Boston ruled against the IRS’ request to rummage through 200,000 pages of church documents.

This Church of Scientology case was observed widely by many religious leaders as the first major test of the law – with an outcome that would be significant for all churches in the United States.

After the Church’s courtroom triumph, the Legal Times reported, “Other church groups are hailing the decision as a victory for religious freedom, and warn that the IRS had better think twice before sticking its nose in religious organizations’ business again.”


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