its rulings and personal disagreement with some of the justices. (9) On April 9, 2021, the President issued Executive Order 14023 that created the Presidential Commission on the Supreme Court (the Commission). Under section 3(iii) of that Executive Order, the Commission was tasked with providing [a]n analysis of the principal arguments in the contemporary public debate for and against Supreme Court reform, including an appraisal of the merits and legality of particular reform proposals. . (10) In December 2021, the Commission released its final report. On the issue of adding justices to the Supreme Court, the Commission concluded [m]irroring the broader public debate, there is profound disagreement among Commissioners on this issue. . (11) Unfortunately, even though the President’s Commission would not endorse adding the number of justices on the Supreme Court, some in Congress still believe it is necessary. See, for example, H.R. 3422, the Judiciary Act of 2023 that would add four associate justices to the Supreme Court. (12) Because of this political uncertainty and the importance that donors in all organizations, no matter their party affiliation, are protected from having their membership disclosed and threats of reprisal that would follow, it is important that Congress statutorily codifies the Supreme Court’s holdings in NAACP v. Alabama ex rel. Patterson and Americans for Prosperity Foundation v. Bonta. (13) Government targeting of tax-exempt organizations because of disagreement with their political views is sadly not a hypothetical problem. From 2010 through 2013, the Internal Revenue Service (IRS) intentionally discriminated against conservative organizations seeking tax-exempt status with words like patriot or Tea Party in their names. (14) After years of litigation, in October 2017, the IRS signed a consent decree in Federal court and admitted to targeting conservative organizations from 2010 through 2013. The IRS confessed that its treatment of [conservative organizations] during the tax-exempt