No. 88-40.

491 U.S. 554 (1989)

109 S.Ct. 2619

105 L.Ed.2d 469


Supreme Court of United States.

Decided June 21, 1989

Attorney(s) appearing for the Case

Alan I. Horowitz argued the cause for the United States. With him on the briefs were Solicitor General Fried, Acting Solicitor General Bryson, Assistant Attorney General Rose, Deputy Solicitor General Wallace, Charles E. Brookhart, and John A. Dudeck, Jr.

Michael Lee Hertzberg argued the cause for respondents. With him on the brief were Eric M. Lieberman and David Golove.*

JUSTICE BLACKMUN delivered the opinion of the Court.

This case arises out of the efforts of the Criminal Investigation Division of the Internal Revenue Service (IRS) to investigate the tax returns of L. Ron Hubbard, founder of the Church of Scientology (the Church), for the calendar years 1979 through 1983. We granted certiorari, 488 U.S. 907 (1988), to consider two issues that have divided the Courts of Appeals. The first is whether, when a district court enforces...

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