Church of Scientology Western United States v. United States of America, Church of Scientology International v. United States

995 F.2d 230 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. CHURCH OF SCIENTOLOGY WESTERN UNITED STATES, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee. CHURCH OF SCIENTOLOGY INTERNATIONAL, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee. Nos. 92-55188, 92-55437. United States Court of Appeals, Ninth Circuit. Argued and Submitted April 8, 1993. Decided June 9, 1993. 1 Before: HALL, WIGGINS, and TROTT, Circuit Judges 2 MEMORANDUM DISPOSITION * OVERVIEW 3 The district court denied motions by the Church of Scientology International and the Church of Scientology Western United States ("Churches") for fees and costs under 26 U.S.C. § 7430 in connection with the quashing of three summonses. The district court concluded that the Churches had failed to establish that the position of the United States was not substantially justified. The Churches appeal, claiming error in the district court's interpretation of the statute. The…