A tax exemption would not only put the imprimatur of the American government on the church as a certified religion, rather than a corrupt, profit-making concern, but it would also provide a substantial amount of immunity from civil suits and the persistent federal criminal investigations. A decision against the tax exemption, on the other hand, would destroy the entire enterprise, because Hubbard had decided in 1973 that the church should not pay its back taxes. Twenty years later, the church was $1 billion in arrears, with only $125 million in reserves.

