| III.
Service Determinations Regarding Scientology-Related Entities.
A.
Issuance of Determination Letters.
Having
received and reviewed the completed Forms 1023, Applications
For Recognition of Exemption and the attachments thereto
for the entities described in paragraphs B.1, B.2, B.3,
B.4, B.5, B.6, B.7, B.8, and B.9 together with requests
for group exemption letters and the attachments thereto
described in paragraphs in paragraphs C.1, C.2, C.3
and C.4, on the basis of that information, the Service
is issuing the individual determination letters and
group determination letters described below and copies
of which are attached at Exhibits III-1 through III-30.
B.
Individual Determination Letters.
1.
The Service hereby issues individual determination letters
(copies attached as Exhibits III-1 through III-5, respectively)
that the following entities are organizations described
in Code sections 501(c) (3), 170(c) (2), 509(a) (1),
and 170 (b)(1)(A)(i):
Religious
Technology Center ("RTC")
Church
of Scientology International ("CSI")
Scientology
Missions International ("SMI")
Church
of Spiritual Technology ("CST")
Church
of Scientology Flag Service Organization, Inc. ("CSFSO")
2.
The Service hereby issues an individual determination
letter (copies attached as Exhibit III-6) that Foundation
Church of Scientology Flag Ship Service Organization
("CSFSSO") is an organization described in Code sections
501(c) (3), 509(a) (1), and 170(b)(1) (A) (i). CSFSSO
is not described in Code section 170 (c) (2) because
it is a foreign entity.
3.
The Service hereby issues individual determination letters
(copies attached as Exhibits III-7 through III-14, respectively)
that the following Scientology-related entities are
organizations described in Code sections 501(c) (3),
170(c) (2), and 509(a) (3):
Inspector
General Network ("IGN")
International
Hubbard Ecclesiastical League of Pastors ("IHELP")
Building
Management Services ("BMS")
Bridge
Publications, inc. ("BPI")
Dianetics
Centers International ("DCI")
Dianetics
Foundation International ("DFI")
Hubbard
Dianetics Foundations ("HDF")
U.S.
IAS Members' Trust
4.
The Service hereby issues individual determination letters
(copies attached as Exhibits III-15 and III-16, respectively)
that the following Scientology-related entities are
organizations described in Code sections 501 (c) (3),
170 (c) (2), 509 (a) (1) and, 170 (b) (1) (A) (vi):
The
Way to Happiness Foundation ("TWTH")
Association
for Better Living and Education ("ABLE")
5.
The Service hereby issues individual determination letters
(copies attached as Exhibits III-17 and III-19, respectively)
that the following Scientology-related entities are
organizations described in Code sections 501 (c) (3)
and 509 (a) (3):
Scientology
International Reserves Trust ("SIRT")
Flag
Ship Trust ("FST")
New
Era Publications International ApS ("NEP")
However,
these organizations are not describe in Code section
170 (c) (2) because they are foreign entities.
6.
Pursuant to a ruling request, the Service hereby modifies
the individual determination letter (copy attached as
Exhibit III-20) that the Church of Scientology Religious
Trust ("CSRT") is an organization described in Code
sections 501(c) (3), 170 (c) (2), and 509(a) (3).
7.
The Service hereby issues individual determination letters
(copies attached as Exhibits III-21 through III-23,
respectively) that the International Association of
Scientologists ("IAS") and its operating arms: Membership
Services Administration, Ltd., and Foundation International
Membership Services Administration d/b/a IAS Administrations,
are organizations described in Code sections 501(c)
(3), and 509(a) (3). IAS and its operating arms are
not described in Code section 170(c) (2) because they
are foreign entities.
8.
The Service hereby issues an individual determination
letter (copy attached as Exhibit III-24) that the Hubbard
College of Administration ("HCA") is an organization
described in Code sections 501(c) (3), 170 (c) (2),
509 (a) (1), and 170 (b) (1) (A) (ii).
9.
Having previously issued a determination letter to the
Church of Scientology Western United States ("CSWUS")
(under the name Church of Scientology of San Diego)
recognizing CSWUS as an organization described in Code
sections 501(c) (3), 170 (c) (2), 509 (a) (1), and 170
(b) (1) (A) (i), and having received and reviewed an
updated Form 1023 and attachments thereto (dated August
30, 1993), the Service hereby issues a revised determination
letter (copy attached as Exhibit III-25) recognizing
CSWUS as an organization described in Code sections
501(c) (3), 170 (c) (2), 509 (a) (1), and 170 (b)(1)
(A) (i).
10.
The Service agrees that the organizations listed in
paragraphs B.1, B.2. and B.9. are churches described
in Code section 6033 (a) (2) (A) (i). Pursuant to Code
section 6033(a) (2), Treas. Reg. [Section] 1.6033-2(g)
(6), and Rev. Proc. 86-23, 1986-1 C.B. 564, the service
determines that the organizations described in paragraphs
B.3, B.5, B.6, B.7, and B.8. are church-affiliated organizations
that need not file annual Forms 990. However, nothing
in this Agreement relieves any Scientology-related entity
from any requirement to file a return (e.g., filing
the Form 990-T in the event of unrelated business taxable
income).
C.
Group Determination Letters.
1.
The Service hereby issues a group determination letter
(as described in Rev. Proc. 80-27, 1980-1 C.B. 677 and
Treas. Reg. [Section] 601.201 (n) (8) (copy attached
as Exhibit III-26)) that the subordinate organizations
of the Church of Scientology International are organizations
described in Code sections 501(c) (3), 170 (c) (2),
509 (a) (1), 170 (b) (1) (A) (i), and 6033 (a) (2) (A)
(i).
2.
The Service hereby issues a group determination letter
(as described in Rev. Proc. 80-27, 1980-1 C.B. 677 and
Treas. Reg. [Section] 601.201(n)(8) (copy attached as
Exhibit III-27)) that the subordinate organizations
of Scientology Missions International are organizations
described in Code sections 501(a) (2) (A) (I), 170 (c)(2),
509(a)(1), 170(b) (1)(A)(i), and 6033 (a)(2)(A)(i).
3.
The Service hereby issues a group determination letter
(as described in Rev. Proc. 80-27, 1980-1 C.B. 677 and
Treas. Reg. [Section] 601.201(n)(8) (copies attached
as Exhibit III-28 and III-29, respectively)) that the
subordinate organizations of the following Scientology-related
entities, are organizations described in Code sections
501 (c) (3), 170 (c) (2), 509 (a) (1), 170 (b) (1) (A)
(ii) (but are not described in Code section 6033 (a)
(2) (A) (I):
Applied
Scholastics Inc.
Hubbard
College of Administration ("HCA")
4.
The Service hereby issues a group determination letter
(as described in Rev. Proc. 80-27, 1980-1 C.B. 677 and
Treas. Reg. Section 601.201(n)(8) (copy attached as
Exhibit III-30)) that the subordinate organizations
of the Citizens Commission on Human Rights ("CCHR")
are described in Code sections 501 (c) (3), 170 (c)
(2), 509 (a) (1), 170 (b) (1) (A) (vi) (but are not
described in Code section 6033(a) (2) (A) (i)).
5.
Subordinate organizations initially covered by the group
exemptions recognized under paragraphs C.1, C.2, C.3
and C.4 are set forth in the following respective Exhibits:
Church
of Scientology International Exhibit III-31
Scientology
Missions International Exhibit III-32
Applied
Scholastics Inc. Exhibit III-33
Citizens
Commission on Human Rights Exhibit III-34
Hubbard
College of Administration Exhibit III-35
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