ORIGINAL

IN THE UNITED STATES CLAIMS COURT
CASE NO. 581-88T

FILED

OCT 15 1990

CHURCH OF SPIRITUAL TECHNOLOGY, Plaintiff,

THE UNITED STATES, Defendant.

PLAINTIFF'S PROPOSED FINDINGS OF FACT

Monique E. Yingling

ZUCKERT, SCOUTT & RASENBERGER

888 Seventeenth Street, N.W. Suite 600

Washington, D.C. 20006 202/298-8660

ATTORNEY FOR PLAINTIFF

Of Counsel:

Thomas C. Spring, Esquire

1130 Seventeenth Street, N.W. Suite 400

Washington, D.C. 20036

IN THE UNITED STATES CLAIMS COURT, Case No. 581-88T

CHURCH OF SPIRITUAL TECHNOLOGY, Plaintiff,

v. THE UNITED STATES, Defendant.

PLAINTIFF'S` PROPOSED FINDINGS OF FACT

I. CST’s FORMATION AND ITS PURPOSE 1

II. THE SCIENTOLOGY RELIGION AND ITS SCRIPTURES 4

III. L. RON HUBBARD’S BEQUESTS TO CST, RTC, AND CSI 13

IV. CST’S ORGANIZATION AND STAFF 22

V. CST’S ACTIVITIES 30

VI. CST’S FINANCES 59

VII. CST'S RELATIONSHIP WITH L. RON HUBBARD AND

THE HIERARCHICAL CHURCH 71

VIII. CST'S ADMINISTRATIVE PROCEEDING BEFORE THE IRS

A. CST's Application For Recognition of Exemption And the

Administrative Proceeding Up to the Initial Adverse Ruling 102

B. The Initial Adverse Ruling 106

C. CST's Protest of the Initial Adverse Ruling.. 109

D. CST'S 1987 Conference 112

E. CST's First Supplemental Submission ................................................................ 114

F. CST's Second Supplemental Submission ............................................................ 117

G. The IRS's Questions Regarding CST's

Relationships With Other Entities ...................................................................... 120

1. FBI and Armstrong Cases ................................................................................ 120

2. Religious Research Foundation ("'RRF"')... 122

3. Cancorp Investment Properties, Inc.

("'Cancorp^') ....................................................................................... 122

4. The International organizations .......................................................................... 123

The On-Site Review ....................................................................................... 130

I. The Aznaran Summons and Interview .............................................................. 152

J. The IRS's Termination of the On-Site Review.. 166

K. The Final Adverse Ruling ................................................................................ 172

INTRODUCTION

This document represents the proposed findings of fact of plaintiff, Church of Spiritual Technology ("CST"), in support of its brief on the merits filed herewith. In these proposed findings and in its brief, CST has used the identification and pagination conventions in defendant's February 5, 1990, Motion for Leave to Give Notice of Citation Forms. Although these proposed findings incorporate portions of CST's prior proposed findings made in connection with defendant's motion to dismiss and CST's cross motion, no cross references to corresponding paragraphs of CST's prior proposed findings have been included CST has prepared a separate Appendix (in 3 volumes) of relevant record materials which support these findings.(note 1).

The structure of section 7428 dictates that the facts in CST's administrative record must be accepted as true.(note 2) Thus, the facts set forth in these proposed findings must be accepted as true unless the record does not support the proposed finding or the record contains other facts which contradict the proposed finding.

It should be noted that CST's administrative record and proposed findings cover a larger period of time than the typical section 7428 case. Ordinarily, the IRS's ruling with respect to a newly-formed applicant will be based only on its proposed activities. Here, however, because of the lengthy administrative proceeding prior to the IRS's ruling on CST's application, CST's record includes not merely its proposed activities but evidence of its actual activities from its formation through April 30, 1987, the end of its 1986 fiscal year. Thus, in most cases, the proposed findings and CST's brief describe CST's actual activities rather than proposed operations. The findings and brief generally speak in the present tense, even though the activities described evolved over several years.

(note 1) In the case of certain lengthy materials, CST's Appendix includes only those pages of particular exhibits pertinent to the proposed findings for which they are cited and additional pages necessary for context. CST's Appendix does not include those exhibits which are cited merely for the fact they are in the record and not for their content.

(note 2) See National Foundation, Inc. v. United States, 13 Cl. Ct. 486 (1987); Easter House v. United States, 12 C1. Ct. 476 (1987); Church of the Visible Intelliqence That Governs the Universe v. United States, 4 C1. Ct. 55, 60 (1983).

I. CST's FORMATION AND ITS PURPOSE

1. Church of Spiritual Technology (MCST"') was organized under the California Nonprofit Religious Corporation Law on May 28, 1982 as a church of the Scientology religion. As provided by Article Three of its Articles of Incorporation, CST's purpose is to:

…espouse, present, propagate, practice, ensure, and maintain the purity and integrity of the religion of Scientology, as the same has been developed and may be further developed by L. Ron Hubbard to the end that any person wishing to, and participating in Scientology may derive the greatest, possible good of the spiritual awareness of his Beingness, Doingness and Knowingness. . . . More particularly, the corporation is formed for the accomplishment, without limitation, of the following more specific purposes:

To serve as a means of promulgating, preserving and administering the religious faith of Scientology throughout the World.

(AR Ex. 1-3; AR pages 1-16 to I-17; CST App. 16-17).

Article Four of CST's Articles of Incorporation provides as follows:

In the conduct of its activities and the accomplishment of its purposes, the corporation shall have, shall enjoy, and may exercise, to their fullest extent, all powers which nonprofit corporations are permitted by law to have and to enjoy; PROVIDED HOWEVER, that:

a. The property of the corporation is irrevocably dedicated to religious purposes, and no part of the income or assets of the corporation shall ever inure to the benefit of any private party or individual; and

b. No substantial part of the activities of the corporation shall be devoted to attempts to influence legislation, by propaganda or otherwise, and the corporation shall not participate or intervene, directly or indirectly, in any political campaign on behalf of or in opposition to any candidate for public office; and

c. The corporation shall not carry on any activities not permitted to be carried on by an organization exempt from federal income tax under Section 501(c)(3) of the Internal Revenue Code of 1954, or successor statutes of similar import; and

d. The corporation shall not-carry on any activities not permitted to be carried on by a corporation described in Section 170(c)(2), contributions to which are deductible under Section 170(a) of the Internal Revenue Code of 1954, or successor statutes of similar import.

(AR Ex. 1-3; AR page 1-18; CST App. 18).

CST's Bylaws state that CST has the “following general goals”:

a. Establishment of a religious body and entity to promote; protect, administer and encourage the religion of Scientology and its goals;

b. Foundation, construction and use of a church, establishments, tutorial schools, retreats, parsonages, centers of training and other centers, for the teaching, dissemination and administration of the religion of Scientology, which aspires to the religious and ethical guidance and improvement of the individual character, and also to better and clarify the human spirit;

c. Assistance in the foundation of Churches of Scientology and other organizations devoted to the religion of Scientology.

d. Publication and distribution of religious literature and other sectarian aids in order to propagate and disseminate Scientology; and

e. Establishment of religious cultural centers.

f. Minister to the spiritual needs of the parishioners and congregants of the Church through the conduct of services, both group and individual.

g. Establishment of a scholarship fund to provide assistance to those seeking advancement on the Scientology Bridge.

h. Establishment and maintenance of a museum devoted to the religion of Scientology.

i. Construction and maintenance of an imperishable structure, capable of withstanding the ravages of nuclear warfare to house the essence of Scientology for the benefit of future generations.

j. Establishment and maintenance of a library devoted to the religion of Scientology.

(AR Ex. 1-4; AR pages 1-26 to 1-27; CST App. 26-27).

CST's specific religious objective “is to preserve and protect the [Scientology] religion so it can be practiced by all generations to come."

(AR Ex. 111-346; AR page 111-95; CST App. 563).

2. CST accomplishes its objective of preserving and protecting the Scriptures of the Scientology faith by making archival-quality copies of the original writings, tapes, films and other materials from which the Scriptures are derived, treating the original materials to preserve them against deterioration, and then storing the treated originals and the archival-quality copies in long-term archival repositories.

(AR Ex.-III-346; AR pages 111-95, 111-144 to 111-157; CST App. 563, 612-625).

3. CST is unique among the Churches of Scientology. It operates independently of and is not part of the Scientology ecclesiastical hierarchy. It has never exercised any authority over any organization within the hierarchy and no organization has exercised any authority over it. It neither ministers Scientology services (other than to its own staff) nor provides any ecclesiastical management or support services.

(AR Ex. III346; AR pages 111-101, 111-124, 111-142 to 111-143; CST App. 569, 592, 610-611).

II. THE SCIENTOLOGY RELIGION AND ITS SCRIPTURES

4. The religion of Scientology evolved from the writings of L. Ron Hubbard, the founder of-the religion and the sole author of its Scriptures. (AR Ex. 1-17; AR page I-100; CST App. 62; AR Ex. 111-346; AR page 111-96; CST App. 564). The religion of Scientology was fully formed by the time CST was incorporated, with voluminous Scriptures that express all the principal practices and fundamental beliefs of its adherents.

(AR Ex. I17;. AR page I-100; CST App. 62; AR Ex. 111-349; AR pages 111-252 to III-1102B).

5. The first church of Scientology was incorporated in 1954. Since then, the religion has grown to an international ecclesiastical hierarchy of hundreds of churches located throughout the United States and abroad. (AR Ex. 1-17; AR page I-100; CST App. 62; AR Ex. 11-76; AR page 11-134; CST App. 320). Individual churches within the ecclesiastical hierarchy minister religious services to Scientology parishioners, or provide ecclesiastical management and support services to other churches, or in the case of some churches, both.

(AR Ex. 11-76; AR pages 11-134 to 11-136, IT-140 to 11-141, 11-142 to 11-143, 11-146 to 11-149; CST App. 320-322, 326-327, 328-329, 332-335).

6. The basic tenet of Scientology is that man is an immortal spirit who has lived through previous lifetimes. Although he has a mind and a body, he is himself a spiritual being. The ultimate goal of Scientology is “a civilization without insanity, without criminals and without war, where the able can prosper and honest beings can have rights, and where Man is free to rise to greater heights." (AR Ex. 111-346; AR page 111-97; CST App. 565).

The principal sacrament in Scientology is "'auditing," which consists of a gradient scale of religious services addressing the spirit. The purpose of auditing is to unburden man of past painful experiences and to orient him as a spiritual being. Auditing results in an increase in spiritual awareness and ability. Ultimately the person achieves certainty of himself as a spirit and freedom from unwanted burdens. At this point he also is certain of immortality.

(AR Ex. 111-346; AR pages 111-97 to 111-98; CST App. 565-566).

Churches of Scientology provide religious auditing services to their parishioners. They also conduct religious training both as seminary training for Scientology ministers and for spiritual enlightenment of parishioners. In training, the Scientologist studies the Scriptures of Scientology to the exclusion of all other materials.

(AR Ex. 111-346; AR page 111-98; CST App. 566).

A fundamental doctrine of the Scientology religion is that spiritual salvation can be attained by following the path Mr. Hubbard outlined in the Scriptures. This path starts with the applied religious philosophy expounded in Dianetics: The Modern Science of Mental Health, which Mr. Hubbard wrote in the early 1950s, and develops on through increasing levels of spiritual enlightenment contained in other texts written by Mr. Hubbard.

(AR Ex. 111-346; AR page 111-98; CST App. 566).

8. The portion of the Scientology Scriptures that constitutes the upper levels of spiritual awareness in the Scientology faith is called the religion's "Advanced Technology."

(AR Ex. 11-76; AR pages 11-247 to 11-248; CST App. 431-432; AR Ex. 111-346; AR page 111-98; CST App. 566).

9. A fundamental doctrine of the Scientology religion is that its religious services must be orthodox. Scientologists must receive religious services directly from and in the manner prescribed by the Scriptures or they will not attain salvation. Scientology churches assure parishioners that their religious services are orthodox by providing them under the imprimatur of certain marks associated with the religion. These Scientology religious marks include the terms "Dianetics," "Scientology" and Mr. Hubbard's name, initials and signature.

(AR Ex. 111-346; AR pages 111-99 to III-100; CST App. 567-568).

10. During his lifetime, Mr. Hubbard asserted full ownership over the Scientology Scriptural materials and religious properties he created, which he provided to the religion in various ways through the many years the religion has been practiced. He provided many Scriptural materials, such as his copyrighted books, directly to the public through formal written licensing agreements with publishing companies related to churches of Scientology. (AR Ex. 11-76; AR pages 11-187 to II195; CST App. 373-381; AR Ex. 111-346; AR page 111-102; CST App. 570). The royalty rates and clauses in these licensing agreements were reasonable and consonant with industry practices and standards. (AR Ex. 11-76; AR page 11-458; CST App. 464).

11. During his lifetime, Mr. Hubbard provided religious instructional films directly to churches of Scientology by providing scripts which were used to produce the films.

(AR Ex. 11-76; AR page 11-196; CST App. 382).

12. During his lifetime, Mr. Hubbard permitted churches to use the Advanced Technology and religious marks through informal verbal agreements that he could terminate immediately for unorthodox practice. (AR Ex. 111-346; AR page 111-102; CST App. 570).

III. L. RON HUBBARD'S BEQUESTS TO CST, RTC, AND CBI

13. In 1982 Mr. Hubbard began considering the future of orthodox Scientology religious practice after-his death. Mr. Hubbard wanted to give the Scientology Scriptures and religious materials to the religion itself, but he thought it more likely that orthodox practice would be compromised sometime in the future if he gave everything to one church. Mr. Hubbard concluded that the best way to ensure orthodoxy for all future years would be to divide rights to the Scriptures among separate churches serving specific religious functions. He believed one church should be responsible for maintaining orthodoxy by performing the exclusive function of supervising religious practice. He also believed that another church should serve as a "fail safe” mechanism to protect the Scriptures in the event they ever were threatened during the millions of years Scientology would be practiced. Mr. Hubbard decided to make his gift to the religion sequentially through three separate gifts.

(AR Ex. 111-346; AR pages 111-102 to 111-103; CST App. 570-571).

14. In May,, 1982 Mr. Hubbard made the first gift by assigning substantial ownership of the religious marks and the right to use the Advanced Technology in the United States to Religious Technology Center ("RTC"), a California nonprofit religious corporation formed on January 1, 1982 for the exclusive purpose of ensuring orthodox practice of the Scientology faith. (AR Ex. 111-371; AR pages 111-1170 to 111-1180; CST App. 721-731; (Advanced Technology); AR Ex. 111-372; AR pages III-1181 to III1229A; CST App. 732-781 (Marks)). Mr. Hubbard required, as a condition of the gifts, that RTC obtain recognition of its exempt status. If not, Mr. Hubbard had the power to appoint RTC's rights to another Scientology organization that already was recognized as exempt. (AR Ex. 111-371; AR pages 111-1173 to 111-1174; CST App. 724-725; AR Ex. 111-372; AR page 111-1187; CST App. 738). Mr. Hubbard also retained the nonexclusive right to certain secular uses of the marks, subject to RTC's approval. This reservation of rights did not include the right to use the Marks in connection with religious services. (AR Ex. 111-372; AR pages 111-1185 to 111-1186; CST App. 736-737).

(See also AR Ex. 111-346; AR pages 111-103 to 111-109; CST App. 571-577).

15. As required by Mr. Hubbard's gifts, RTC delegates rights to use the Advanced Technology and religious marks to qualified churches in the ecclesiastical hierarchy. RTC then supervises their activities to ensure-compliance with Scriptural requirements. (AR Ex. 111-346; AR page 111-105; CST App. 573). Churches that minister the Advanced Technology to their parishioners provide RTC with six percent of the contributions they receive with respect to such services. (AR Ex. 111-346; AR page 111-108; CST App. 576). This funding is intended to support the religion of Scientology in general more than RTC's particular religious activities. (AR Ex. VII-591; CST App. 987). Pursuant to the terms of Mr. Hubbard's gifts, RTC must apply 90 percent of such funds it may receive to religious and charitable purposes that are either "within purposes of the religion of Scientology" or "'for the general purpose of advancing the moral and ethical level of mankind." (AR Ex. 111-371; AR page 111-1174; CST App. 725).

(See also AR Ex. 111-346; AR pages 111-105 to 111-108; CST App. 573-576).

16. Church of Scientology International ("'CSI"'), a California nonprofit religious corporation, was formed in 1981 (AR Ex. 11-76; AR pages 11-143 to 11-144; CST App. 329-330) and is the ecclesiastical Mother Church of Scientology. As the Mother Church, CSI exercises ecclesiastical authority over all churches and missions of the religion that are part of the hierarchical church. (AR Ex. 11-76; AR page 11-147; CST App. 333).

RTC has granted CSI the license to use the marks in connection with services rendered by CSI pertaining to the Scientology religion. This grant extends to all of the organizations under the ecclesiastical authority of CSI that expressly agree and covenant to abide by the conditions of the grant to CSI and that recognize RTC as the protector of the religion. In return, CSI has agreed that RTC shall be the final authority with respect to decisions regarding protection of the religious marks. (AR Ex. II-76; AR page II-171; CST App. 357).

17. Mr. Hubbard made the second gift, also in May 1982, by giving CST the power to acquire RTC's rights to the Advanced Technology and religious marks if, and only if, any one of three narrowly-defined conditions occurs: (1) RTC fails to maintain the "'ethical use"' of the property 'in accordance with the Scientology Scriptures," (2) the property is ^'in danger of appropriation by an entity outside of or hostile to the religion,"' or (3) RTC permits the property to be used in a way that both "is contrary to the Scientology Scriptures” and “seriously damages the religion of Scientology or the image or reputation of L. Ron Hubbard." (AR Ex. 1-21; AR pages 1-138 to 1-144; CST App. 65-71 (Marks); AR pages 1-191 to 1-196; CST App. 118-123

(Advanced Technology) ). (See also AR Ex. 111-346; AR pages 111-109 to III-110; CST App. 577-578).

18. Mr. Hubbard granted the options to CST because CST was not subject to or part of the authority of the ecclesiastical hierarchy. Mr. Hubbard believed CST had to be independent of the hierarchical church with no responsibility for its actions to ensure that any decision it made with respect to the options would be objective. (AR Ex. 111-346; AR pages 111-104, 111-110;

CST App. 572, 578). Mr. Hubbard did not impose any obligation on CST to monitor use of the marks or the Advanced Technology or otherwise undertake any activity with respect to the options.

(AR Ex. 1-21; AR pages 1-138 to 1-144; CST App. 65-71 (Marks); AR pages I-191 to 1-196; CST App. 118-123 (Advanced Technology)).

19. Upon his death on January 24, 1986, Mr. Hubbard made the third gift by transferring-to CST the bulk of his estate, including all of his copyrights to the Scriptures and his remaining rights in the marks and Advanced Technology, on the condition that CST obtains recognition of its tax-exempt status. This transfer was made through Mr. Hubbard's Last Will and Testament and through a revocable inter vivos trust. Mr. Hubbard transferred to his trust all property he owned, other than his intellectual properties and a few investment assets, which passed under his will. If CST does not obtain recognition of its exemption, Mr. Hubbard directed that his estate be distributed to one or more organizations described in Code section 501(c)(3) that operate exclusively for the purposes of the Scientology religion.

(AR Ex. 111-346; AR pages III-111 to 111-115; CST App. 579-583).

20. Mr. Hubbard's third gift included all his retained right over the Scientology marks and Advanced Technology, his patents concerning religious articles, and the copyrights to all of his Scriptural writings, as well as to his fictional works. The index of titles to his copyrights runs over 800 pages. A court-appointed referee appraised Mr. Hubbard's probate estate at $26,305,706, almost all of which -- $25,000,000 -- was attributable to Mr. Hubbard's intellectual properties. (AR Ex. 111-346; AR pages III-111 to 111-115; CST App. 579-583).

21. Mr. Hubbard's bequest to CST included the following copyrighted materials:

HCO Policy Letters -- Over 6,000 published issues concerning matters of ecclesiastical administration dating from 1957.

HCO Bulletins -- Over 4,000 published issues concerning the ministration of Scientology religious services dating from 1954.

Miscellaneous Issues -- Over 800 miscellaneous issues, directives and orders concerning various ecclesiastical matters dating from 1957, including Flag Orders, Central Bureau Orders, L. Ron Hubbard Executive Directives and Professional Auditor's Bulletins.

Compilations -- Over 120 volumes of compilations of issues, directives, bulletins, etc. concerning ecclesiastical matters and the ministration of religious services dating back to 1950, including Hubbard Communication Office (“HCO”) Management Series, HCO Executive Course, HCO Technical Bulletins, HCO Office Board Policy, HCO Office Policy, HCO Office Bulletins and HCO Chronological Packs.

Lecture Tapes -- Over 3,000 tape recordings of lectures on the religion and on the ministration of religious services dating from 1950.

Films -- Over 110 instructional films on the Scientology religion and the ministration of Scientology religious services.

(AR Ex. 111-349; AR pages III-252 to III-11028).(note 3)

(note 3) Due to its volume, CST has not included Mr. Hubbard's estate inventory in its Appendix.

IV. CST'S ORGANIZATION AND STAFF

22. CST is an autonomous organization. It is governed by its own officers and staff.

(AR Ex. 1-38; AR page 1-352; CST App. 161). It maintains its own books and records and its own bank accounts, and it disburses its funds only for purposes that have been approved in advance by its staff as accomplishing its religious program. (AR Ex. 1-17; AR page I-1o1; CST App. 63; AR Ex. III346; AR page 111-135; CST App. 603).

23. During the relevant periods, CST's staff has ranged from 15 to 63 highly-dedicated Scientologists-who work exclusively for CST.

(AR Ex. 1-17; AR page 1-98; CST App. 60 (15 staff in mid-1984); AR Ex. 1-40; AR page 1-358; CST App. 167 (36 staff in late 1984); AR Ex. 111-346; AR page 111-125; CST App. 593 (55 staff in mid-1987); AR Ex. 11-76; AR page 11-184; CST App. 370 (63 staff in mid-1986)).

24. CST staff must be members of Scientology's religious order, the Sea Organization, which means they have signed a formal agreement committing themselves to the Scientology religion for the next billion years.

(AR Ex. 111-346; AR page 111-125; CST App. 593; AR Ex. VII-588; CST App. 983).

25. CST staff are required to live free of the distractions of the secular world and stand ready to attend to their religious duties at any time day or night. They eat communally in CST-provided dining rooms and live communally in CST-provided berthing.

(AR Ex. VII-756; CST App. 1197).

CST staff members generally work from 8:30 a.m. to 11:00 p.m. each day, with one day off every other week. (AR Ex. VII-684; CST App 1151).

26. CST maintains an extensive religious program for its staff. CST's ministers provide pastoral counseling, give spiritual advice, minister to the spiritual needs of CST's staff and perform sacerdotal functions such as namings, marriages and funerals. CST staff participate in religious observances six days each week where they receive the principal sacrament of Scientology, as well as training in the Scriptures. CST also has a formal program for the training and ordination of its ministers (AR Ex. 111-346; AR page 111-142 to 111-143; CST App. 610-611), although CST sends its ministers to other churches of Scientology for higher levels of ministerial training because CST does not have staff qualified to provide the needed training.

(AR Ex. VII-741; CST App. 1183; AR Ex. VII-754; CST App. 1184-1193).

27. CST requires all staff to devote two and one-half hours each day to the study of the Scientology Scriptures, technical materials related to their work, and ministerial training.

(AR Ex. VII-773; CST App. 1208).

28. CST's Bylaws require that its Trustees meet very rigid religious requirements to qualify both for election to the Board and for continued service on the Board. For example, candidates for election to the Board must

(1) have a good, uninterrupted record of at least eight years as an “ethical and loyal Scientologist,"

(2) have attained a specified high level of spiritual awareness,

(3) be "'well versed in the technology of Dianetics and Scientology" and have "applied this technology to help others, with excellent results,"

(4) be "'well versed in the administrative policy of organizations affiliated with the religion of Scientology" with "demonstrated success in the utilization and application of such policy,"

(5) be "an ordained Scientology minister, in good standing pursuant to those principles set forth in the Scriptures," and

(6) be "'well versed in the Scientology Ethics and Justice System."'

(AR Ex. 111-346; AR pages 111-117 to 111-118; CST App. 585-586).

CST's standards are more stringent for Trustees who wish to continue serving on the Board. As provided by its Bylaws, Trustees must, within ten years of appointment, achieve four specified levels of the highest religious-and ecclesiastical training. They also must spend a minimum of 12-1/2 hours each week receiving religious services or training toward attaining these four levels. (AR Ex. 111-346; AR page 111-118; CST App. 586).

Once Trustees satisfy the ten-year requirement, they must continue to meet very high religious standards. CST's Bylaws require that after their ten-year anniversary of service, Trustees must continue receiving or giving at least 12-1/2 hours of services or training each week.

(AR Ex. 111-346; AR pages 111-118 to 111-119; CST App.-586-587).

CST's General Directors also must meet high standards of religious accomplishment. As required by its Bylaws, each General Director must be a duly-ordained minister of Scientology in good standing with the Mother Church, well-versed in the Scriptures and the Scientology Ethics and Justice System, and a proven religious executive, as demonstrated by actual performance.

(AR Ex. 111-346; AR page 111-120; CST App. 588).

29. CST compensates its staff at a subsistence level, providing them with meals, berthing, child care, official Sea Organization uniforms, medical and dental assistance and other essentials, and a nominal weekly allowance of $30 for personal items such as clothing, toiletries and cigarettes. Staff also may receive small bonuses each year based upon how well they performed their religious duties. (AR Ex. VII-756; CST App. 1197).

The average pay received by CST staff during the years in question was approximately $3,800 per year (note 4)

For example, the four CST officers named below received compensation from CST as full time staff members during fiscal year 1986. In addition to the reported cash compensation, these individuals (like other staff members) also received room, board and other essentials which were furnished to them by the organization. All the compensation paid was in their capacity as staff members, not as officers, directors or trustees:

Dan Przybylski $6,072

Nancy O’ Meara $4,016

Russ Bellin $4,964

Leo Johnson $3,355

Total: $18, 407

(AR Ex. VII-581; CST App. 977).

(note 4) This approximate amount was determined by dividing the average yearly total staff compensation for fiscal years 1982 through 1986 ($160,159.00 -- see CST PF 65) by the average size of CST's staff for the years in question (42 staff members -- see CST PF 21).

V. CST'S ACTIVITIES

30. Since it was formed in 1982, CST has devoted all of its staff time and expenditures to providing religious services and training to its staff and to preserving the Scientology Scriptures. (AR Ex. III-346; AR page 111-140; CST App. 608).

31. CST's preservation activities have been substantial, ongoing and concern every medium in which the Scriptures exist -paper, tape and film. Since its mission is to ensure that the Scriptures will be available for all future generations, CST must be sure that the mediums on which the Scriptures are preserved will last millions of years. CST will accomplish its goal by using the most advanced techniques available to preserve the original materials (to the extent a technique exists) and by making multiple archival copies of the originals on different mediums that can be replaced with more durable materials as better preservation methods evolve. Multiple copies on different mediums give CST more flexibility in choosing copying processes in-the future and better ensure that at least one set of the Scriptures will be available in the event the originals and several sets of copies are somehow destroyed.

(AR Ex. 111-346; AR pages 111-144 to 111-146; CST App. 612-614).

32. CST's administrative offices and main preservation facility are located on a 54-acre, 15-building compound located near San Bernardino, California that CST purchased for $2.3 million in October 1985, approximately three years after it was formed.

(AR Ex. VII-594; CST App. 1123; AR Ex. VII-819; CST App. 1236-1254).

33. CST’s offices and main preservation facility were in major disrepair when CST purchased it, and over the next eighteen months CST devoted more than $400,000 and a considerable amount of staff time to renovating some of the buildings and improving the property.

(AR Ex. VII-573; CST App. 923; AR Ex. VII-594; CST App. 1123)

34. CST uses every structurally-sound building to further its preservation program, although several of the buildings are uninhabitable and require major renovations. It uses eight buildings for staff housing and dining, one as a workshop and another as a gate-house.

(AR Ex. VII-594; CST App. 1123).

CST conducts its preservation and archival activities and temporarily stores the original Scriptures in its 6,000 square-foot preservation building.

(AR Ex. VII-722; CST App. 1164-1165).

CST extensively renovated this building to protect the original Scriptural materials from fire, pollutants and other elements.

(AR Ex. 111-352; AR pages 111-1126 to 111-1127; CST App. 696697).

35. CST installed multiple layers of sheet rock in the ceiling and floor of its preservation building to give them a two-hour fire rating and it installed fire-rated doors as well as temperature and humidity controls and air cleaners. (AR Ex. 111-352; AR page 111-1127; CST App. 697).

36. Since it was formed, CST has devoted most of its preservation activities to the written Scientology Scriptures.

The original manuscripts of the Scientology Scriptures are very extensive -- they include over 500,000 pages of separate "issues" or pronouncements on the ministration of religious services and ecclesiastical administrative matters and 297 books, 261 pamphlets, essays, and summaries, 855 magazines, 355 course compilations, and 142 reference compilations on Dianetics and Scientology. In addition to original, handwritten versions of the issues, CST has the official "mimeo" or published versions of the issues.

(AR Ex. 111-346; AR pages 111-115, 111-145 to III147; CST App. 583, 613-615).

37. As a necessary first step in the preservation process for written materials, CST must locate and collect the original version of each writing. CST collects these originals from Scientologists and Scientology churches located throughout the world. (AR Ex. 111-346; AR page 111-145; CST App. 613). CST's collection activities have been extensive. Its first collection trip was to the Church of Scientology in Washington, D.C. in 1985. (AR Ex. V-534; AR page V-35; CST App. 819). Since then, CST has sent staff on collection missions to Canada, England, Denmark, Australia, Germany and Switzerland and throughout the United States. (AR Ex. 111-346; AR page 111-145; CST App. 613). From mid-1985 through mid-1987, CST spent more than $220,000 for travel. (AR Ex. VII-580; CST App. 951; AR Ex. VII-581; CST App. 962).

With one minor exception, all original writings CST has collected have been provided to it as gifts in recognition of the contribution to society of CST's preservation program. (AR Ex. V-534; AR page V-35; CST App. 819). The sole exception to these gratuitous gifts occurred in late 1985 when CST learned that a Scientologist living in England possessed a number of early Professional Auditor Bulletins and early technical bulletins, many fully or partially handwritten by Mr. Hubbard. On this parishioner's death, his wife contributed these valuable originals of the Scriptures to CST. In exchange, his wife was awarded some religious services at the Church of Scientology in London, her home. (AR Ex. V-534; AR page V-36; CST App. 820).

38. As writings are located and collected, they are delivered to CST's archival facilities and sorted, categorized and filed temporarily in environmentally-controlled facilities. The writings then undergo copying and preservation processes. (AR Ex. 111-346; AR page 111-146; CST App. 614).

39. Before preserving the original writings, CST makes seven copies of each original. It makes two copies on a microfilm that has a life span of at least 100 years and five copies on an acid-free paper and ink with a 1,000-year life span, called "Durable Masters." CST anticipates this duplication stage will take a long time. It already has taken CST staff two years to microfilm the original issues, which consist of 500,000 pages, and CST estimates that it will take several years to reproduce an entire set of the original written issues on Durable Masters. CST has yet to reproduce the articles, books, transcripts, notes and other writings that make up the written Scriptures. (AR Ex. 111-346; AR pages 111-146 to 111-148; CST App. 614-616).

40. After CST reproduces the written Scriptures, it will preserve the paper itself by putting it through a deacidification process to prevent deterioration from the acid contained in the paper. CST then will encapsulate the deacidified paper in clear, archival mylar plastic envelopes that have a life span in excess of 1,000 years. (AR Ex. 111-346; AR pages 111-148 to 111-149; CST App. 616-617).

41. As the final step in the paper preservation process, CST will place the encapsulated originals in gas-filled time capsules similar to those used by the National Archives for preserving the Constitution and the Declaration of Independence, which CST then will store in a special long-term storage facility designed just for the originals. (See CST PF 52, 56). CST also will place sets of the Durable Masters and microfilm copies in fire-proof, gas-filled containers and store them in its other archival facilities. Other sets will be available as sources for current research.

(AR Ex. 111-346; AR pages 111-149 to 111-150; CST App. 617-618).

42. The Scriptures of the Scientology religion include over 42 films of lectures Mr. Hubbard gave on Dianetics and Scientology in the late 1950s and early 1960s and instructional films on the technology of the religion that were written or directed by Mr. Hubbard. CST plans to maintain a complete set of the original films in its archives and store a complete set of duplicates in each of the three vault repositories it will construct. At present, CST is storing the originals of the films in special environmentally-controlled storage facilities at CST's studio for production of religious films. (AR Ex. 111-346; AR page 111-150; CST App. 618).

43. CSI has completely refurbished many original scriptural films that were produced in the mid-1960s and that had become faded and scratched through extensive use over the years. CSI also produced a limited number of the films, and CST acquired four sets of them to preserve in its storage vaults. (AR Ex. VII-864; CST App. 1257).

44. To date CST only has collected original Scriptural film. It has yet to begin reproduction and preservation, although after extensive research, it has concluded that the best method for preserving original film will be through a color separation process.

(AR Ex. 111-346; AR page 111-150; CST App. 618).

This process requires expensive equipment to separate the colors and screen them out of the film, leaving it black and white, a state in which it can be stored for a much longer time

than color film. (AR Ex. 11-76; AR page 11-234; CST App. 419).

45. CST has found that existing laboratories cannot perform this color separation process at the high quality standards desired and that their work in any event would cost over $1 million. CST may purchase the necessary equipment and process the film on its own, although current estimates are so expensive -- $350,000 for the equipment and approximately $150,000 to process each set of film -- that CST is still in the planning stage.

(AR Ex. 111-346; AR pages 111-150 to 111-151; CST App. 618-619).

46. CST constantly monitors the industry for new developments in film preservation. It is particularly interested in preservation techniques that record film images in digital format for storage on laser discs. While existing equipment can do this, CST is not satisfied with the resolution of the finished product. This technology is still evolving, however, and CST expects that better quality discs may be available soon and that it-eventually will be able to use this process. (AR Ex. 111-346; AR page 111-151; CST App. 619).

47. A very important source of Scientology scriptures are the recordings of Mr. Hubbard's lectures on Scientology and Dianetics, which date back to as early as 1946. CST has over 6,500 master reels of original recordings of Mr. Hubbard's lectures, including over 900 small plastic disc recordings of lectures Mr. Hubbard gave between 1946 and 1950 called "Soundscriber discs." (AR Ex. 111-346; AR page 111-151; CST App. 619).

48. CST already has made seven complete sets of each master lecture and Soundscriber discs on magnetic tape. This project took ten CST personnel over two years to complete and has cost over $1.3 million in tape and studio equipment. In all, CST has made four archival quality copies on reel-to-reel magnetic tape that it will store in its archival facilities and two copies on cassette tape that it will use for research purposes. It also has made a non-archival quality tape that it will provide to CSI. CSI will use this tape to transcribe Mr. Hubbard's master recordings into 100 two to three-inch thick volumes. In exchange for this tape, CSI will provide CST with one set of the 100 volume transcription which CST can preserve. (AR Ex. 111-346; AR pages 111-151 to 111-152; CST App. 619-620; AR Ex. 111-352; AR page III-1135C; CST App. 708).

49. CST is not satisfied with the life of magnetic tape and has been researching mediums that have a longer life. This research has led to digital sound technology, which CST believes holds great promise for the future. Digital sound technology has the added benefit of enabling CST to reconstruct audio information that is lost when the oxide covering wears off from very old, frail tapes. At present, CST is setting up a digital production line to convert the analog signals on magnetic tape to digital signals, which CST will record on special archival quality videotape. CST plans to record all 6,500 master reels special archival-quality video tape. CST estimates that this project will cost $200,000. (AR Ex. 111-346; AR pages 111-152

on to 111-153; CST App. 620-621; AR Ex. 111-352; AR page III-1135G; CST App. 712).

50. Since video tape has about the same life as magnetic tape, CST plans eventually to store the digital version of Mr. Hubbard's lectures on a longer lasting medium, such as laser discs. However, currently available mass-produced laser discs (which consist of aluminum plated plastic) have an even shorter life span than magnetic tape, so CST has been exploring special, archival laser discs made of more durable materials. In initial stages of its research, CST made a prototype disc of chrome plated glass for $1,800 but found the medium unworkable. Subsequently, it concluded that discs made of gold plated glass may prove to be the best medium for long-term storage, but current production costs are too high -- it would cost approximately $6.5 million to record one set of the master reels on these laser discs. Until costs are reduced, or a more practical medium is found, CST will continue to make digital versions of the recording on video cassette tape. (AR Ex. III346; AR pages 111-152 to 111-153; CST App. 620-621; AR Ex. III352; AR pages III-1135H to 111-11351; CST App. 713-714).

51. In addition to preserving the actual media containing the written and spoken words of Scientology Scriptures, CST must house both the originals and the archival copies of the Scriptures in a way to ensure that they will be available for millions of years. In light of the limitations of current technology, CST has decided that its vaults must have a minimum life of 1,000 years. To meet these specifications, CST has thoroughly researched such matters as vault design, specifications, engineering, tunneling methods, materials and doors. It also spent one year inspecting numerous potential sites and investigated the effects of local geology as well as the potential effects of earthquakes, floods and nuclear war. (AR Ex. 111-346; AR page 111-154; CST App. 622; AR Ex. 111-352; AR page III-1135J; CST App. 715).

52. For the present, CST plans to store the archival copies in three long-term vault repositories that it will construct. (AR Ex. 111-346; AR page 111-154; CST App. 622). CST already has purchased sites for two repositories for its-archival copies, a 3,520-acre tract in New Mexico, which it purchased in 1984 for $250,976, (AR Ex. VII-804; CST App. 1228; AR Ex. VII-805; CST App. 1229-1235), and two tracts of land in Northern California totaling approximately 3,000 acres, (AR Ex. VII-594; CST App. 1127), which it purchased in 1983 for $1,500,000. (AR Ex. VII798; CST App. 1218-1222; AR Ex. VII-799; CST App. 1223; AR Ex. VII-800; CST App. 1224-1227). CST has not yet purchased property for its third repository, which it plans to locate outside the United States. It also will store the originals of the Scripture in a special repository it will construct at its main preservation facility in San Bernardino, California. (AR Ex. 111-346; AR pages 111-154 to 111-156; CST App. 622-624).

53. CST began work on the New Mexico project late in the summer of 1985 and retained a general contractor to construct the vault in October 1985. (AR Ex. VII-648; CST App. 1133-1141). CST then spent about a year researching proper design of the vault. Before beginning work, CST had to provide for basic necessities such as access, living quarters, water, etc. CST also had to prepare the vault itself before it could begin drilling by reinforcing the facing of the site ($65,000), building a work pad ($130,000) and installing a hoist ($65,000).

(AR Ex. 111-352; AR pages III-1135J to III-1135M; CST App. 715718).

54. CST had to alter its initial design once construction actually began as a result of unknown defects in the vault sites. In the first 50 feet of drilling, CST encountered four major rock fissures, each of which required $90,000 and weeks of work to fix. When exploratory drilling showed six more fissures in the next 200 feet, CST decided to redesign the vault to avoid them. As redesigned, the New Mexico vault totals 500 feet, consisting of a 200-foot entrance tunnel that will fork into two separate storage tunnels, each 150 feet in length. The tunnel has a three to four-inch thick concrete lining and a drainage system patterned on systems used in Swiss railway tunnels. The vault will have four doors with a maintenance-free life of 1,000 years. Two of the doors will be nuclear blast resistant and constructed out of stainless steel, corrosion-resistant steel and concrete and will weigh approximately 6,500 pounds each. They will cost $120,000. CST estimates that the total cost of this one vault will exceed $2 million. (AR Ex. 111-346; AR page 111-155; CST App. 623; AR Ex. 111-352; AR pages III-1135N to 111-11350; CST App. 719-720).

55. CST currently is in the planning stage with respect to the other long-term vaults it will construct, though it expected to begin site preparation and initial construction for the second vault in early 1988. CST projects the cost to construct the other two vaults (and to purchase the final site) at over $5 million. Construction of living facilities will cost another $50,000 to $100,000 per site. (AR Ex. 111-346; AR page 111-156; CST App. 624).

56. CST plans to construct a separate underground storage facility at its preservation facility in San Bernardino to house the original scriptural materials. This vault will be similar to the long-term vault repositories but will have more extensive environmental controls and other special features such as air conditioning, humidity controls and a halon gas fire extinguishing system in light of the fragile condition of the originals. CST estimates this vault will cost approximately $750,000 to construct. (AR Ex. 111-346; AR pages 111-156 to 111-157; CST App. 624-625).

57. CST often must carry out its own research program to develop the equipment and techniques necessary to meet its demanding specifications. CST's research staff are highly trained and experienced technical experts capable of researching the most advanced methods in preservation technology. CST's research personnel work closely with archival professionals, chemists and engineers and leading manufacturers of state-of-the art products. They keep abreast of technological advances by attending trade shows and conferences and by reviewing reports of new developments by organizations such as the Library of Congress Preservation Office, the National Archives, the National Bureau of Standards, and the American National Standards Institutes. (AR Ex. 111-346; AR page 111-157; CST App. 625).

58. The work of CST's research personnel is ongoing and includes research concerning the following:

1. Microfilm. CST conducted extensive research on archival micro-filming techniques and equipment for reproducing the original written scriptures.

2. Color Separation. CST has conducted substantial research concerning color separation as a preservation process for the original film tape.

3. Durable Paper and Ink. CST researched and explored with major manufacturers the longest-lasting archival paper and ink to use for copying the Scriptures on Durable Masters.

4. Digital Audio. CST spent approximately two years researching digital recording to determine if it could be used to record the Scripture's lectures in accordance with CST's archival standards.

5. Laser Discs. CST also has researched archival laser discs as a method to preserve scriptural film and tape, including gold and glass archival laser discs.

6. Respooling. CST conducted research concerning special respooling equipment and techniques to preserve magnetic recording tapes.

7. Soundscriber Discs. CST conducted research on special techniques to preserve copies of discs.

8. Environmental Conditions. CST conducted extensive research concerning the ideal storage conditions for every type of material to be archived, both originals and copies, including proper temperature and humidity controls, air and ultra-violet filters, fireproofing, sealing materials and security devices.

9. Archival Xerography. After extensive research, CST concluded that xerography could be a viable archival process if used with the archival paper and ink it developed to produce Durable Masters.

10. Binding. CST has researched and developed an archivally-certified binding method to bind the packs of Durable Masters it is creating for issues and for books.

11. Deacidification. CST is researching various methods to neutralize the acid content of paper and deposit an alkaline buffer that prevents future environmental contamination. CST will use this process to preserve all written originals.

12. Encapsulation. CST is researching archival mylar plastics and plans to preserve all original written materials by encapsulating them through this sealing process.

13. Time Capsules. CST is researching airtight containers filled with inert gas to house the original materials for storage.

14. Vault Construction. CST personnel spent a year actively researching vault structures best suited for housing the Scriptures, both originals and copies, including the most durable materials for vault construction, tunneling methods and vault design. CST also surveyed different sites to determine the best geological location for the vaults.

15. Vault Doors. CST conducted extensive research to identify doors and manufacturers of doors capable of resisting natural and man-made disasters while also remaining maintenance free for over 1,000 years.

16. E-Meter Research. CST has engaged in research along with an outside research firm, Action Enterprises, to develop an E-Meter (a religious artifact used in delivering Scientology religious services to parishioners) that can be used by highly aware spirits who are exterior to bodies.

(AR Ex. VII-604; CST App. 1129-1130). This research will assist spirits to attain total spiritual freedom by ensuring that Scientology's technology is available through the most advanced procedures.

(AR Ex. 111-346; AR pages 111-157 to 111-161; CST App. 625-629).

CST research personnel also have developed and/or implemented certain new techniques and devices related to its preservation functions. Some of these new developments in the field of sound recording include: development of speed analyzer equipment; engineering of a special tone generator; a special grounding bar; and development of a micrometer adjustable playback head. (AR Ex. 111-346; AR page 111-161; CST App. 629).

VI. CST'S FINANCES

59. Through 1986 CST funded its activities primarily with voluntary grants from other churches of Scientology and from its investment income. (AR Ex. 111-346; AR pages 111-135 to 111-136; CST App. 603-604). To preserve its independence from the ecclesiastical hierarchy, CST was not willing to accept contributions with restrictions beyond those resulting from its Articles of Incorporation, Bylaws, and religious doctrines. (AR Ex. 1-29; AR page I-229; CST App. 147). Article Four of CST's Articles of Incorporation provides:

C. The corporation shall not carry on any activities not permitted to be carried on by an organization exempt from federal income tax under Section 501(c)(3) of the Internal Revenue Code of 1954, or successor statutes of similar import.

(AR Ex. 1-3; AR page 1-18; CST App. 18).

60. In 1983 CST received a one-time start-up grant of $17,959,745.00 from Church of Scientology Flag Service Organization ("'CSFSO"'). CST provided nothing to CSFSO in exchange for this grant.

(AR Ex. 111-346; AR pages 111-135 to 111-136; CST App. 603-604; AR Ex. VII-578; CST App. 924-934).

CSFSO is a Florida nonprofit religious corporation that is situated in Clearwater, Florida. Its parishioners are Scientologists from foreign countries and the United States and staff members from other churches who travel to CSFSO to take the highest levels of auditing and training in the Scientology Advanced Technology. (AR Ex. 11-76; AR page 11-168; CST App. 354).

61. CST has received unrestricted grants from RTC as follows:

Fiscal Year -Grant

1982 $ 623,137.00

1983 1,905,125.00

1984 1,282,113.00

1985 2,029,949.00

1986 2,792,211.00

TOTAL $ 8,632,535.00

(AR Ex. 1-2; AR page 1-6; CST App. 5; AR Ex. 1-17; AR page I-100; CST App. 62 (1982); AR Ex. VII-578; CST App. 924-934 (1983); AR Ex. VII-579; CST App. 935-949 (1984); AR Ex. VII-580; CST App. 950-960 (1985); AR Ex. VII-581; CST App. 961-979 (1986)). These grants bear no relationship to the few instances in which CST provided copies of Scriptural materials to CSI or RTC. (Entire Record).

62. RTC provided CST these grants pursuant to the terms of Mr. Hubbard's gift of the Advanced Technology, which requires RTC to apply 90 percent of the funds it receives with respect to the use of the Advanced Technology to religious and charitable purposes. (AR Ex. 111-346; AR page 111-108; CST App. 576). Since one purpose suggested in Mr. Hubbard's gift is

“establishing and maintaining an indestructible record of the Scientology Scriptures" (AR Ex. 111-371; AR page 111-1174; CST App. 725), RTC elected to grant the 90 percent amounts to CST in those years. CST anticipates that RTC may reduce its level of funding once CST receives Mr. Hubbard's estate. (AR Ex. 111-346; AR page 111-136; CST App. 604).

63. CST has funded a portion of its program with interest earned from its bank accounts:

Fiscal Year Interest Earned

1983 $ 812,954.15

1984 1,677,560.00

1985 1,320,655.00

1986 1,035,112.00

Total 4,846,281.15

(AR Ex. VII-578; CST App. 924 (1983); AR Ex. VII-579; CST App. 935 (1984); AR Ex. VII-580; CST App. 950 (1985); AR Ex. VII-581; CST App. 961 (1986)).

64. CST has a few other small sources of financial support in addition to its grant and interest income. It has received rent from one property on which it plans to construct a storage vault in the future:

Fiscal Year Rental Income

1983 $12,500.00

1984 15,000.00

1985 15,000.00

1986 17,500.00

Total 60,000.00

CST has realized gains from currency exchanges:

Fiscal Year Exchange Gain Income

1985 $ 262,580.00

1986 129,023.00

TOTAL $ 391,603.00

CST has realized income from the occasional sales of assets such as automobiles and timber:

Fiscal Year Income

1985 $ 2,705.00 (timber)

1986 1,750.00 (automobiles)

TOTAL $ 4,455.00

CST has received occasional small payments from other churches of Scientology for Field Staff Member ("'FSM"') commissions: (note 5)

(note 5) FSMs generally are independent Scientology ministers who receive commissions for their fundraising activities on behalf of (footnote continued)

Fiscal Year Income

1984 $ 1,925.00

1985 705.00

1986 1,660.00

TOTAL $ 4,290.00

CST has received reimbursement for the cost of duplicating Scriptural material:

Fiscal Year Reimbursement

1984 $ 23,149.00

1985 4,525.00

1986 9,113.00

TOTAL $ 36,787.00

(AR Ex. VII-578; CST App. 924-934 (1983); AR Ex. VII-579; CST App. 935-949 (1984); AR Ex. VII-580; CST App. 950-960 (1985); AR Ex. VII-581; CST App. 961-979 (1986)).

(footnote continued from previous page)

a particular Scientology organization delivering religious services to the public. (AR Ex. 11-76; AR pages 11-392 to II397; CST App. 442-447). Church staff sometimes perform FSM services, and when they do, the fund raising commissions are paid to the church for which the staff member works. (AR Ex. 11-76; AR pages 11-392 to 111-396; CST App. 442-446).

CST has never had FSMs. (AR Ex. 11-76; AR page 11-392; CST App. 442).

65. During the years in issue, CST incurred the following operating expenditures:

Employee Compensation

1982 9,608

1983 46,896

1984 147,231

1985 268,751

1986 328,309

Total 800, 795

Professional Fees

1982 16,431

1983 69, 476

1984 145, 714

1985 508,249