The US Court of Appeals for the Sixth Circuit held today that the names, addresses, and other identifying information of applicants for tax-exempt status are not return information for purposes of section 6103. As such, the court required the IRS to produce the applicant names and related information regarding the organizations whose applications for exempt status were identified for heightened scrutiny. United States v. NorCal Tea Party Patriots, 2016 BL 87076, 6th. Cir., No. 15-3793, 3/22/16.