From: hkhenson@my-deja.com
Newsgroups: alt.religion.scientology,misc.legal
Subject: Re: Henson loses- again
Date: Thu, 02 Nov 2000 20:09:20 GMT
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In article <8tr1po02rms@drn.newsguy.com>,
  Court_Watch <Court_Watch_member@newsguy.com> wrote:
> H. KEITH HENSON, Plaintiff-Appellant, v. INTERNAL REVENUE SERVICE,

snip

> Furthermore, Henson lacked standing as a federaltaxpayer because the
> first amended complaint failed to allege an injury resulting from
> Congress's exercise of power under the taxing and spending clause. See
> Flast v. Cohen (1968)


UNITED STATES COURT OF APPEALS

FOR THE NINTH CIRCUIT

_____________________________
				       |
H. KEITH HENSON,		       |	No. 99-17038
		Plaintiff-Appellant,   |
				       |	D.C. No CV-98-21290-JW
	v.			       |
				       |	PETITION FOR
INTERNAL REVENUE SERVICE	       |	REHEARING
		Defendant-Appellee.    |	(EN BANC)
____________________________	       |

REASON:  Material point of fact overlooked in decision.

		The first amended complaint alleged two independent
grounds for standing, either of which would have permitted the case to
go forward. Both were denied.  The appeal affirmed on the two
independent grounds, the first of which (remoteness of injuries by
Scientology facilitated by the IRS) plaintiff concedes.  However, a
material fact was overlooked in rejecting on the second grounds:

	"Furthermore, Henson lacked standing as a federal
taxpayer because the first amended complaint failed to allege an
injury resulting from Congress's exercise of power under the
taxing and spending clause."

		The court made a plain error, overlooking page 14,
starting at line 7 of the first amended complaint:

	"Revenue Ruling 93-73 provides direct benefits to the
members of the Church of Scientology, and Federal taxpayers
are compelled [emphasis added] to subsidize Scientology
education courses that may be "contrary to their consciences."

		The plaintiff is identified as a "Federal taxpayer" on
page 3, line 6 of the first amended complaint.  Plaintiff being
compelled in any dollar amount to subsidize Scientology education
courses contrary to my conscience is no less of an injury to me than the
injury an Orthodox Jew would feel if he were compelled by the government
to eat pork.

		The above injury flows from Congress's exercise of power
under the taxing and spending clause of the Constitution because
Congressdelegated taxing authority to the IRS in the Revenue code under
that power. Revenue Ruling 93-73 is explicitly connected in the first
amended complaint to Congress's power and to a violation of the
Establishment clause (which limits taxing and spending powers) on page
13 line 1:

	"Revenue Ruling 93-73 advances Scientology by allowing
its members to deduct as charitable contributions payments
made to the Church in quid pro quo transactions which are
denied to other religions under Section 170."  [of the Revenue
Code]

		En Banc considerations are to be requested only on
certain grounds such as "the proceeding involves a question of
exceptional importance."  Exhibit A, an article from the September 4,
2000 issue of Forbes magazine shows that a member of another faith was
denied equal treatment by the IRS on religious grounds (not being a
Scientologist) and that the scale of tax write-offs (if equal treatment
were not denied) exceeds ten billion dollars per year.

		Respectfully submitted,



		H. Keith Henson, pro se

		September 5, 2000


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[Editorial note:  The September 5, 2000 date in this Usenet posting
was incorrect, but corrected before filing.]