"If the state would be allowed to tax religious and spiritual organizations, it would have the power to control them by modulating taxes. As the U.S. Supreme Court stated in the 1819 decision “,” “the power to tax involves the power to destroy.” American legal scholar Ken Jacobsen has discussed the implications of this principle for the Tai Ji Men case. Religious liberty thus requires that religions be tax-exempt, and the exemption in fact preserves the principle of separation rather than denying it."