The plaintiffs, tax-exempt atheist organizations, challenged the exemption for churches contained in I.R.C. Sec. 6033(a)(3) from filing Form 990 that most other tax-exempt organizations must file. The court dismissed the case for lack of standing on the basis that the plaintiffs never sought an exemption from the Form 990 filing requirement and never showed any interest in seeking such an exemption. Freedom From Religion Foundation, et al. v. Koskinen, No. 12-cv-946-bbc, 2014 U.S. Dist. LEXIS 174017 (W.D. Wis. Dec. 17, 2014).