Form 906

Rev. January 1987

Department of the Treasury -- Internal Revenue Service

A. Code section 6104 Public Inspection File.

1. The Code section 6104 public inspection file for Church of Scientology International shall include a Form 1023 with information and financial data for taxable years 1989, 1990, and 1991. In addition, the Code section 6104 public inspection file for CSI shall include agreed upon portions of the Qualified Written Material. These documents and the resulting determination letter shall be the only materials considered as the application, supporting papers and determination information described in Code section 6104(a)(1)(A) with respect to Church of Scientology International.

2. The Code section 6104 public inspection file of each Scientology-related entity (other than Church of Scientology International) to be recognized as exempt under section III. paragraph B. hereof shall include the individual Form 1023 with information and financial data for taxable years 1989, 1990, and 1991, previously submitted by the Church. With respect to the parent Scientology-related entities listed in section III. paragraph C., the Code section 6104 public inspection file shall include a group exemption request with information for taxable years 1989, 1990, and 1991, as previously submitted by the Church. Each such application shall incorporate by cross-reference the application and Code section 6104 public inspection file of Church of Scientology International as described in paragraph A.1. These documents, including Church of Scientology International's Code section 6104 public inspection file incorporated by reference and the resulting determination and ruling letters, shall be the only materials considered as the application, supporting papers and determination information described in Code section 6104(a)(1)(A) for each remaining Scientology-related entity to be recognized as exempt pursuant to this Agreement.

3. The Service shall close without action exemption determination applications by the following Scientology-related entities:

Religious Technology Center ("RTC")

Church of Scientology International ("CSI")

International Hubbard Ecclesiastical League of Pastors ("IHELP")

The Way to Happiness Foundation ("TWTH")

Association for Better Living and Education ("ABLE")

Church of Scientology Celebrity Centre Dallas

Church of Scientology of Georgia

Church of Scientology Mission of New Jersey

RTC, CSI, IHELP, TWTH and ABLE submitted revised and updated Forms 1023 and are being recognized as exempt under paragraph B. of section III. of this Agreement. The remaining three entities are being recognized as subordinate entities under group exemptions being recognized under paragraph C. of section III. of this Agreement.

4. All information submitted in connection with the closed applications as described in paragraph A.3., and all information submitted in connection with this Agreement other than that listed in paragraph A.1. and A.2., including but not limited to (i) all Qualified Written Material information not specifically included as part of the Code section 6104 public inspection file of Church of Scientology International pursuant to paragraph A.1., and (ii) this Agreement itself, shall be considered to be return information described in Code section 6103(b)(2).

B. Disclosure of Information by the Service.

1. The Service shall maintain the information described in section V. paragraph A.4. of this Agreement in the office of the Assistant Commissioner and shall disseminate such information within the Service only to the extent the Assistant Commissioner determines it necessary for the administration of the Code (including actions taken in administering this Agreement).

2. The Service shall not disclose any information described in section V. paragraph A.4. of this Agreement, including but not limited to this Agreement itself, to any third party other than as permitted under Code section 6103 or otherwise as permitted under applicable law or under this Agreement.

3. The Service agrees to use its best efforts to notify the CTCC of any litigation against the Service by a third party to compel production of information described in section V. paragraph A.4. of this Agreement.

C. Disclosure of Information by the CTCC.

1. The CTCC may use information described in section V. paragraph A.4. only to the extent necessary to carry out its obligations hereunder to inform Church parishioners of the provisions of section VII of this Agreement.

2. The CTCC may use information described in section V. paragraph A.4. only to the extent it determines it is necessary in connection with any tax matter by any state or local governmental body in the United States or by any foreign governmental body. To minimize the extent of such disclosure, the Service agrees to certify the effect of relevant provisions of this Agreement to any other governmental taxing authority upon request by the CTCC and following consultation with the CTCC concerning the text of such certification. This paragraph C.2. of this section V in no way limits the obligations or discretion of the Service with the respect to governmental taxing authorities under section 6103.

3. The CTCC shall not produce information described in section V. paragraph A.4. of this Agreement, including but not limited to this Agreement itself, except to the extent allowed under this section V. It is the specific intent of the Parties that such materials, including but not limited to this Agreement itself, shall not be the subject of discovery in any civil litigation between a third party and any Scientology-related entity or individual, and the CTCC agrees not to produce such information in such circumstances except to the extent disclosure is compelled by a court of competent jurisdiction after exhaustion of all available judicial review. The parties agree that the provisions of this paragraph C. of this section V. are the result of shared concerns regarding confidentiality. Except in carrying out the provisions of paragraph C. of this section V., the CTCC agrees not to assert or otherwise publicly characterize this Agreement in a manner that would indicate that the Service has required that information under this Agreement be kept confidential.

D. Proceeding Under Agreement. Notwithstanding any other paragraph of this section V, information described in section V. paragraph A.4. of this Agreement may be disclosed in any proceeding to construe or enforce any provision of this Agreement or in any proceeding relating to the federal tax liability of any Scientology-related entity. Inthe event disclosure becomes necessary under this paragraph D., the parties agree to use their best efforts to file all information described in section V. paragraph A.4. under seal so that it does not become part of the public judicial or administrative record.

E. Disclosure Following Inquiries. The CTCC agrees that the Service, in response to inquiries, may characterize the information in the section 6104 public inspection files and may acknowledge the existence of an agreement that has settled a variety of longstanding issues between the Church and the Service, including exemptions from tax as well as a variety of outstanding tax and litigation matters. In addition, in response to such inquiries, the Service may disclose that there is a Closing Agreement concerning the nature and extent of permissible disclosure by the Service in light of the requirements of Code section 6103 and acknowledge the existence and extent of tax information authorizations submitted pursuant to this Agreement and the Settlement Agreement.

F. Correction of Misstatements. Either the Service or the CTCC may disclose information described in section V. paragraph A.4. of this Agreement in the event of a misstatement of fact or mischaracterization published or disclosed about the contents of,the effects of, or reasons for, this Agreement or matters related thereto. Information described in section V. paragraph A.4. may be disclosed for this purpose only to the extent necessary to correct the misstatement or mischaracterization and only if the Assistant Commissioner and the CTCC have consulted prior to such disclosure.

G. Term of Undertaking. Paragraph A. of this section V. applies as long as the Service retains any of the information described in paragraph A. The remaining paragraphs of this section V. apply only through December 31, 1999.