Church of Scientology of California v. United States of America and Sandra Baker, Revenue Officer

The Church of Scientology of California (Church) appeals from the denial of its request for a preliminary injunction against the Internal Revenue Service (IRS). The district court concluded it lacked subject matter jurisdiction and, therefore, was precluded from granting this relief by the Anti-Injunction Act, 26 U.S.C. § 7421 . The Church contends that the record demonstrates that the district court has the jurisdiction to grant equitable relief pursuant to the judicial exception to the Anti-Injunction Act. We disagree and affirm.

I

This case arises from an action filed by the Church against the IRS in which it alleged:

1. Wrongful disclosure of taxpayer information under 26 U.S.C. § 6103 by improperly issuing bank levies and individual assessments.

2. Violation of the First Amendment of the United States Constitution by engaging in unlawful and arbitrary actions against the Church motivated “by an impermissible hostility to the Scientology religion.”

3. Violation of the due process clause of the Fifth Amendment by treating the Church and its parishioners differently from other religions.

4. Violation of the due process clause by failing to follow established IRS…