FOIA requires that Federal agencies publish in the Federal Register and make available for public inspection certain specified materials. All other agency materials must be available upon request unless they fall within one of nine exemptions to the act. FOIA exemption 3 provides an exemption to the act. FOIA exemption 3 provides an exemption from mandatory disclosure when the information sought is exempted specifically from disclosure by another statute as long as the other statute either leaves the agency no discretion in withholding documents or establishes specific guidelines to govern the withholding process. Part I of this article analyzes Church of Scientology v. IRS (Church I, 1986), in which the D.C. Circuit held that material sought under authority of section 6103 of the Internal Revenue Code fails within FOIA exemption 3 and that FOIA's de novo standard of review, therefore, applies to IRS decisions to withhold information under section 6103. The article concludes that the court's position, which is consistent with the position of a growing number of the circuit courts, is correct. Part II of the article examines the D.C. Circuit Court's broad interpretation of the Haskell Amendment to section 6103 of the Internal Revenue Code in Church of Scientology v. IRS (Church II, 1986). In this case the court required public disclosure of only a limited class of tax documents. 132 notes