In May 2013, then–President Barack Obama gave a press conference in which he expressed dismay at a recent report out of his administration. "If in fact IRS personnel…were intentionally targeting conservative groups," he said, "then that's outrageous. And there's no place for it." He later promised to get to the bottom of "these failures," which he called "intolerable and inexcusable," and insisted that those involved be held to account. "Regardless of how this conduct was allowed to take place," he said, "the bottom line is, it was wrong."

These remarks followed a disclosure by the IRS that organizations with right-coded terms such as tea party and patriots in their names had been subjected to heightened scrutiny when applying for tax-exempt status. This targeting of groups on the basis o

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