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ox 22, 1989 JE S MRELNTSHISo0: 1340226061 h : Honorable Lester 2. Urets Shiof counsel Internal Rovenwe Service Waehington, Ds Cy 20226 Bet Founding church of Sclentology v. United States Dear tir, Ureter . Gio principal toaue in the abovoestated:cace 1s whather the alleged church 19 oxespt fron federal incone taxation as a roligious organization within the meaning of Section $01(¢)(3) of tho Internal Revenue Cede of 1954, As wo view it, thore are essentially tvo questions Involved in our casa, The first {2 whether scientolosy io a “raligion, The socond $c whethor the alleged church is really | a profitensking erjanlzation for certain indjvidualss y ‘This organteotion was founded by L. Row Hubbard, a sclonco ficthon writer in 1955, an outgrowth of an ecarlior movonent called “Dianctice’. The alleged church 1s located at 1312 = 19th Stroet, janhington, D. 2., with bracches in aluost overy major city in tha United States. It 1s part of an international | organization with headquarters in England, and branches in Franco; West Gornany; Australia; Nov Zealand; and South Africa. el Le Ron Hubbard who ts still tho leader of acientolosy explains An his Litorature that it was established ag a churci in order to be protected fro nodical practice lavs and te provide tha practitioners with an avenue of access as ministers into hospitals, insane asyluns, poaitontiarios and other restricted places. The church orgerization has also boon Cescribed to individuals by tts uenbors to be a “tax dedze". Consequently, many individuals untrainod in psychiatry have become practitionars of tho organization and have modo tholt activities a nosna of livelihood, Luring the taxable years in Iscua, the organization prozoted and sold on electrical devica called the “Zeloter" for the auditing of Individuals, who paid $22 an hour for this gorvica; an oloctric current wns pacsed through tho subject as in @ Mo-detactor causing cortain nourophysical offocts, It marketed a pill called "fisnozane" which it clained could provent tho radiation effects resulting trom ateate boad testing. Noroover, it appeara that the Founding church claizs the ability to cure diseases, including cancer, having discovored th: ultinata aeerots of life and tha univorse, On January 4, 1963, approxinatoly 14 deputy marshals and sovoral Food and Drug Adatatotration inspectors * geisad at loact 100 packazea and boxes of pazghlots and several dozen boxea of clectrical gadgets as the Goverazont moved against its Washington headquarters, This action has resulted in a considerable ezount of publicity cad congrosaionai inquiry, sinco the “church” argues that the gadsots aro roligious instruments for uso as part of its "confossional”,. Additional complaints regarding tho Founding Church's operations havo bosn made to local polica stations, acdical sasociations, psychiatric assoclations, better businoss burcous and atote welfare departaenta. 7 Im tha preparation of our dofense in this caso, we desire eertain information concerning tho various sciontolozical organiza tions and individuals connectod therewith. le aro aspectally Antereated in davoloping ovidence and witnosses knowledgeable in the background and operations of this organtzstion and its affiltates. Accordingly, wo have attached a list of Imovn sclentological groups and affilfates, individuals acttve in tho movonent, and public and private organications which hove received sorious complaints regerding scientology operations. Ve are also interested in substantiating tha validity of Le Ron Hubbard's acadente and professional background. Va, therefore, request that u oupplenental investigation be dnstitited in order to ascertain In detail the opocified information. “If any of the individuals interviews’ night be unable as witnesses in this cave, it would be noat belpiul if you coulé indleste their anes und business addresses. Copies of correspondence, books, Becounts or other tangible things rulevent to the sbeve-nentioned Yocues should also be mage. | Thank you for your ascistance. Sinserely yours, 4 MITCHELL ROGOVIN Assistont Attornsy General Tex Division INLE M. TUREER Chief, Court of Claims Section