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CHURCH OF SCIENTOLOGY OF CALIFORNIA v. C.I.R.

No. 85-7324.

823 F.2d 1310 (1987)

CHURCH OF SCIENTOLOGY OF CALIFORNIA, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided July 28, 1987.

Attorney(s) appearing for the Case

Christopher Cobb, Pasadena, Cal., Richard Riley, Washington, D.C. and Eric Lieberman, New York City, for petitioner-appellant.

Steven Frahm, Washington, D.C., for respondent-appellee.

Lee Boothby, Berrien Springs, Mich. and Gerald McNally, Jr., Glendale, Cal., for amicus-curiae.

Before TANG and BRUNETTI, Circuit Judges, and JAMESON, District Judge.

TANG, Circuit Judge:

The Church of Scientology (Church) appeals a judgment of the Tax Court which affirmed the Commissioner's assessment of tax deficiencies and late filing penalties against the Church for the years 1970, 1971 and 1972. At issue is whether the Commissioner properly revoked the Church's tax exempt status.

I.

The Church was incorporated as a non-profit corporation in the State of California in 1954. In 1957, the Commissioner recognized...

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