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The Conference Committee Report to the Tax Reform Act of 1984 contains the following information: “In Fiscal Year 1983, the IRS closed 6,612 examinations involving alleged church tax avoidance schemes, assessing $23,803,200 in taxes and penalties (an average assessment of $3,600 per return) and leaving a calendar year--end inventory of 15,296 church tax avoidance cases (in addition to approximately 200 criminal investigations). In the first six months of Fiscal 1984 alone . . . the IRS assessed $25,620,178 in taxes and penalties in 5,498 cases relating to church tax avoidance schemes. The conferees specifically intend that nothing in the church audit procedures will inhibit IRS inquiries, examinations, or criminal investigations of tax protestor or other tax avoidance schemes posing as religious organizations, including (but not limited to) tax avoidance schemes posing as mail--order ministries or storefront churches . . . .”