Many religious individuals make contributions to their religions. And in many cases, they can deduct those contributions. Contributions cease to be deductible, though, to the extent the donor gets something of value in exchange. And what counts as value? While that is easy to answer for the most part, on the religious margins, it is a difficult question. The Supreme Court, for example, held that Scientologists’ auditing (a religious activity that helps them achieve their spiritual goals) was value, and, as a result, held that Scientologists could not deduct the cost of auditing. The IRS ultimately accommodated Scientologists, permitting them to deduct the costs of auditing in spite of the religious benefit they derived. And the IRS’s accommodation led to Orthodox Jewish taxpayers claiming the ability to deduct a portion of their children’s religious school tuition. The courts again held that, because they were paying for education, the tuition was nondeductible.