The First Amendment is designed to prevent such a result. The Tax Commission considered the apparent inconsistency of Rev. Haugen, in setting forth financial figures, to be significant. However, respondent did not set forth any objective standards as to how high a percentage of revenues devoted to salaries can be before it is considered excessive. A struggling Jewish or Protestant congregation, for example, may have to pay much of its meager earnings to a rabbi or minister and still be a bona fide religious group. The mere fact that Scientology permits members to continue as Jews or Christians does not destroy its character as a religion.
Nothing requires a religion to exclude all other religions or belief systems.
Hindus and Buddhists, for example, borrow greatly from other religions. Jews and Christians have learned much from each other and share the Old Testament as a common heritage. The mere fact that L. Ron Hubbard's son is engaged in litigation involving the father's finances does not mean that the church is run for profit or that the Hubbards have misused church funds. The Tax Commission gave considerable weight to newspaper articles and other items outside the record in an effort to demonstrate that Scientology is not a bona fide religion. The matters contained in these articles may well be relevant, but the respondent's determination must be based, at least in part, on direct testimony.