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==Significant individuals and organizations== {{Category see also |Holocaust deniers}} In the immediate aftermath of the war, before the Allied forces had fully documented the extent of the Holocaust, many people reacted with disbelief and even denied the first reports of what had happened.<ref name="FoguKansteiner2016">{{cite book |first1=Claudio |last1=Fogu |first2=Wulf |last2=Kansteiner |first3=Todd |last3=Presner |title=Probing the Ethics of Holocaust Culture |url=https://books.google.com/books?id=2MRADQAAQBAJ&pg=PA68 |date=October 17, 2016 |publisher=[[Harvard University Press]] |isbn=978-0-674-97051-9 |page=68}}</ref> Compounding this disbelief was the memory of [[Fake news|forged newspaper accounts]] of the [[German Corpse Factory]], an anti-German [[atrocity propaganda]] campaign during WWI, which was widely known to be false by 1945.<ref name="BBC fake news">{{cite news |title=The corpse factory and the birth of fake news |url=https://www.bbc.co.uk/news/entertainment-arts-38995205 |access-date=March 5, 2017 |work=[[BBC News]] |date=February 17, 2017 |archive-url=https://web.archive.org/web/20170228230334/http://www.bbc.com/news/entertainment-arts-38995205 |archive-date=February 28, 2017}}</ref> During the 1930s, the Nazi government used this propaganda against the British, claiming allegations of concentration camps were malicious lies put forward by the British government, and historians Joachim Neander and [[Randal Marlin]] note that this story "encouraged later disbelief when early reports circulated about the Holocaust under Hitler".{{R|BBC fake news}} [[Victor Cavendish-Bentinck]], chairman of the British Joint Intelligence Committee, noted that these reports were similar to "stories of employment of human corpses during the last war for the manufacture of fat which was a grotesque lie"; likewise, ''[[The Christian Century]]'' commented that "The parallel between this story and the 'corpse factory' atrocity tale of the First World War is too striking to be overlooked."<ref name="bgd">{{cite book |last=Neander |first=Joachim |title=The German Corpse Factory. The Master Hoax of British Propaganda in the First World War |publisher=[[Saarland University Press]] |date=2013 |page=8–9}}</ref> Neander notes that "There can be no doubt that the reported commercial use of the corpses of the murdered Jews undermined the credibility of the news coming from Poland and delayed action that might have rescued many Jewish lives."<ref name="bgd"/> The [[Neo-Nazi]] movement has been revitalized by Holocaust denial. Small but vocal numbers of neo-Nazis realized that recreation of a Hitlerite-style regime may be impossible, but a replica might be produced in the future; the rehabilitation of Nazism, they concluded, required the discrediting of the Holocaust.<ref name=Atkins>{{cite book |first=Stephen E. |last=Atkins |title=Holocaust Denial as an International Movement |url=https://books.google.com/books?id=M9Uj6u6b-ZIC |year=2009 |publisher=[[ABC-CLIO]] |isbn=978-0-313-34538-8 |quote=Holocaust denial has played an important role in the revitalization of the Neo-Nazi movement. There was a smaller but nonetheless vocal number of supporters in other Western European countries and the United States. These neo-Nazis realized that a Hitlerite regime was impossible, but a reasonable facsimile was possible in the future. These neo-Nazis and their allies realized that any rehabilitation of Nazism could be accomplished only by discrediting the Holocaust.}}</ref> [[Neo-fascism]] has likewise relied upon Holocaust denial as a means of rehabilitation.<ref>{{Cite journal |last=Bland |first=Benjamin |date=2019 |title=Holocaust inversion, anti-Zionism and British neo-fascism: the Israel–Palestine conflict and the extreme right in post-war Britain |url=https://www.tandfonline.com/doi/full/10.1080/0031322X.2018.1536347 |journal=[[Patterns of Prejudice]] |language=en |volume=53 |issue=1 |pages=86–97 |doi=10.1080/0031322X.2018.1536347 |issn=0031-322X |access-date=May 11, 2024 |archive-date=May 11, 2024 |archive-url=https://web.archive.org/web/20240511134816/https://www.tandfonline.com/doi/full/10.1080/0031322X.2018.1536347 |url-status=live}}</ref> As a movement, modern Holocaust denial is associated with historical revisionism based on [[pseudoscience|pseudoscientific]] evidence<ref name="Rosenfeld2015">{{cite book |last1=Rosenfeld |first1=Alvin H. |title=Deciphering the new antisemitism |date=2015 |location=Bloomington and Indianapolis |publisher=[[Indiana University Press]] |isbn=9780253018694 |pages=250, 350 |url=https://books.google.com/books?id=ibfkCgAAQBAJ |quote="In the 1970s, Holocaust denial took up more sophisticated pseudoscientijfic methods and began to portray itself as a movement of historal revisionists..." |access-date=March 21, 2023 |archive-date=July 5, 2024 |archive-url=https://web.archive.org/web/20240705094703/https://books.google.com/books?id=ibfkCgAAQBAJ |url-status=live}}</ref><ref name="Pigliucci_Philosophy_of_Pseudoscience_2013">{{cite book |last1=Pigliucci |first1=Massimo |last2=Boudry |first2=Maarten |title=Philosophy of pseudoscience : reconsidering the demarcation problem |date=2013 |publisher=[[University of Chicago Press]] |location=Chicago |isbn=9780226051826 |pages=206 |url=https://archive.org/details/philosophyofpseu00unse/page/206/ |access-date=February 13, 2023}}</ref><ref name="Brittingham2020">{{cite journal |last1=Brittingham |first1=Matthew H. |title="The Jews love numbers": Steven L. Anderson, Christian Conspiracists, and the Spiritual Dimensions of Holocaust Denial |journal=[[Genocide Studies and Prevention]] |date=September 2020 |volume=14 |issue=2 |pages=44–64 |issn=1911-0359 |eissn=1911-9933 |doi=10.5038/1911-9933.14.2.1721 |pmid= |s2cid=225256338 |url=https://digitalcommons.usf.edu/cgi/viewcontent.cgi?article=1721 |quote="The preacher produced a nearly 40-minute video, "Did the Holocaust Really Happen?," in which he espoused what Deborah Lipstadt has called "hardcore" Holocaust denial, "den[ying] the facts of the Holocaust" in an "outright and forceful fashion." Though his “scientific” evidence for the "Holocaust hoax" or "Holocaust myth," as he often refers to the Holocaust, is mostly a regurgitation of the pseudoscientific arguments made by a more established group of Holocaust deniers, Anderson adds a spiritual dimension to Holocaust denial to make it attractive to Christian viewers." |doi-access=free}}{{Dead link|date=May 2023 |bot=InternetArchiveBot |fix-attempted=yes }}</ref><ref name="HirvonenKaristo2022">{{cite journal |last1=Hirvonen |first1=Ilmari |last2=Karisto |first2=Janne |title=Demarcation without Dogmas |journal=[[Theoria (philosophy journal)|Theoria]] |date=February 13, 2022 |volume=88 |issue=3 |pages=701–720 |issn=0040-5825 |eissn=1755-2567 |doi=10.1111/theo.12395 |pmid= |hdl=10138/345499 |s2cid=246834442 |url=https://philarchive.org/rec/HIRDWD |quote="On the one hand, there is science denialism, such as climate change scepticism, the anti-vaccination movement, and holocaust denial, which attacks well-established scientific theories and practices. On the other hand, there is the promotion of pseudotheory, the attempt to get doctrines like homoeopathy and intelligent design accepted as sciences even though they have no warrant for such merit (Hansson, 2017). Both types of pseudoscience have harmful effects on health, environment, education, and society...Paradigmatic pseudosciences can also be very different from one another. Think of, say, intelligent design, Holocaust denial, ancient astronaut hypothesis, homoeopathy, the anti-vaccine movement, astrology, or climate change scepticism. Because there are different forms of pseudoscience, one cannot rule out the possibility that different criteria are needed to distinguish them from science." |hdl-access=free}}</ref> and [[fringe science|fringe academic networks]]<ref name="Rosenfeld2015"/><ref name="Pigliucci_Philosophy_of_Pseudoscience_2013"/> including [[Diegesis|intradiegetic]] pseudoscientific journals,<ref name="CODOH_ADL">{{cite news |title=Committee for Open Debate on the Holocaust (CODOH) {{!}} Center on Extremism |url=https://extremismterms.adl.org/glossary/committee-open-debate-holocaust-codoh |access-date=February 13, 2023 |work=extremismterms.adl.org |publisher=[[Anti-Defamation League]] |date=2022 |language=en |archive-date=February 13, 2023 |archive-url=https://web.archive.org/web/20230213142838/https://extremismterms.adl.org/glossary/committee-open-debate-holocaust-codoh |url-status=live}}</ref> conferences, and professional organizations (e.g. ''[[Journal of Historical Review]]'', [[International Conference to Review the Global Vision of the Holocaust]], [[#Bradley Smith and the CODOH|Committee for Open Debate on the Holocaust]]).<ref name="HolocaustEncyclopedia_2001">{{cite book |last1=Laqueur |first1=Walter |last2=Baumel-Schwartz |first2=Judith Tydor |title=The Holocaust encyclopedia |date=2001 |location=New Haven |publisher=[[Yale University Press]] |isbn=9780300084320 |pages=300 |quote="Holocaust revisionism enlists a wide variety of strategies and assumes many different forms adapted to the history and political cultures in which it operates. It has nonetheless developed into an international movement with its own networks, gatherings, public forums, propaganda, and pseudo-scientific journal"}}</ref><ref name="NESS_HD">{{cite news |last1=Novella |first1=Steven |title=Holocaust Denial |url=https://theness.com/index.php/holocaust-denial |access-date=February 13, 2023 |work=[[New England Skeptical Society]] |date=July 17, 2009 |quote="Those who deny that there ever was a Nazi genocide of Jews during World War II have used a similar style of arguing. Deniers have subjugated science, in this case historical science, to a political agenda, creating a pseudoscience called Holocaust Denial.... Inventing and promoting pseudoscience [the art of using "expert witnesses"]: Leuchter claims that the gas chamber was not really used against human beings.... Error #1: Leuchter estimates that a certain crematorium at Auschwitz could process only 156 bodies. He was apparently unaware of an SS report which confirms that the same building (which he describes) destroyed 4756 bodies in the course of a single 24 hour period. Error #2: He notes that the cyanide residue from one gas chamber wall is less than the residue from a wall inside a known delousing chamber. Leuchter claims that this is the most conclusive evidence that a "gas chamber" could not have been used for killing humans. His argument is based on the assumption that humans require much more cyanide than lice to die – an assumption that, as it happens, is wrong. In fact, lice require about a 50 times higher dose of cyanide gas than humans in order to die." |archive-date=February 12, 2023 |archive-url=https://web.archive.org/web/20230212144941/https://theness.com/index.php/holocaust-denial/ |url-status=live}}</ref><ref name="Whine2008">{{cite journal |last1=Whine |first1=Michael |title=Expanding Holocaust Denial and Legislation Against It |journal=Jewish Political Studies Review |date=2008 |volume=20 |issue=1/2 |pages=57–77 |jstor=25834777 |url=https://www.jstor.org/stable/25834777 |access-date=February 13, 2023 |issn=0792-335X |quote="Holocaust deniers, and the media they use, are changing as a consequence of international political developments... New forms of this propaganda encompassed pseudoscientific books and papers; crude denial material, usually published in leaflet form by small neo-Nazi groups; and what can be called political denial, which includes the most recent and increasingly potent source, namely, Islamists as well as Internet and television transmissions within some Muslim states. Many of the pseudoscientific publications available internationally were published under cover of fictitious academic publishing houses. These works included, for example, ''The Hoax of the Twentieth Century'' by Arthur Butz, ''Did Six Million Really Die?'' by Richard Harwood, and ''The Leuchter Report''. Historians challenged these and rebutted their false theses."}}</ref> ===Maurice Bardèche=== The first person to openly write after the end of World War II that he doubted the reality of the Holocaust was French art critic [[Maurice Bardèche]] in his 1948 book {{lang|fr|Nuremberg ou la Terre promise}} ("Nuremberg or the Promised Land").<ref name=":2">{{harvnb|Igounet|2000|p=31}}: "{{lang|fr|Pour la première fois, depuis la fin de la guerre, un homme écrit qu'il doute ouvertement de l'existence des camps de la mort}}" [For the first time, since the end of the war, a man writes that he openly doubts the existence of death camps]</ref> In the 1950 book ''Nuremberg II, ou les Faux-Monnayeurs'', designed around the tale of [[Paul Rassinier]], a former deportee from [[Nazi concentration camps]] (not to be confused with [[extermination camps]]) turned into a Holocaust denier, Bardèche concluded that [[Kapo (concentration camp)|kapos]] were in reality worse than [[Schutzstaffel|SS]], and expressed his "doubts" about the existence of gas chambers.{{sfn|Igounet|2000|p=}}{{page needed|date=August 2024}} Viewed as "the father-figure of Holocaust denial",<ref>{{Harvnb|Barnes|2002|p=195}}: "Bardèche being considered as the father-figure of Holocaust denial and its methodology"</ref><ref>{{Cite book |last=Der Matossian |first=Bedross |author-link=Bedross Der Matossian |url=https://books.google.com/books?id=TOq1EAAAQBAJ&pg=PA1952 |title=Denial of Genocides in the Twenty-First Century |date=2023 |publisher=University of Nebraska Press |isbn=978-1-4962-3554-1 |quote=In the postwar period, the two main Holocaust deniers were the French journalist Maurice Bardèche, considered “the father-figure of Holocaust denial,” and the American historian Harry Elmer Barnes.}}</ref> Bardèche introduced in his works many aspects of [[neo-fascist]] and Holocaust denial [[propaganda techniques]] and ideological structures; his work is deemed influential in regenerating post-war European far-right ideas at a time of identity crisis in the 1950–1960s.{{sfn|Algazy|1984|pp=208–209}}{{sfn|Barnes|2002|p=}}{{sfn|Bar-On|2016|p=}} His arguments formed the basis of numerous works of Holocaust denial that followed: "testimonies are not reliable, essentially coming from the mouth of Jews and communists", "atrocities committed in camps were the work of deportees [essentially the [[Kapo (concentration camp)|kapos]]]", "disorganization occurred in Nazi camps following the first German defeats", "the high mortality is due to the 'weakening' of prisoners and epidemics", "only lice were gassed in [[Auschwitz concentration camp|Auschwitz]]", etc.{{sfn|Igounet|2000|p=}}{{page needed|date=August 2024}} ===Harry Elmer Barnes=== [[Harry Elmer Barnes]], at one time a mainstream American historian, assumed a Holocaust-denial stance in his later years. Between [[World War I]] and [[World War II]], Barnes was an [[anti-war]] writer and a leader of the [[historical revisionism]] movement. Starting in 1924, Barnes worked closely with the [[Centre for the Study of the Causes of the War]], a German government-funded think tank whose sole purpose was to disseminate the official government position that Germany was the victim of Allied aggression in 1914 and that the [[Versailles Treaty]] was morally invalid.{{sfn|Herwig|1987|pp=22–23 & 26}} Headed by Major Alfred von Wegerer, a {{lang|de|[[Völkisch movement|völkisch]]}} activist, the organization portrayed itself as a scholarly society, but historians later described it as "a clearinghouse for officially desirable views on the outbreak of the war."{{sfn|Herwig|1987|pp=21–23 & 26}} Following World War II, Barnes became convinced that allegations made against Germany and [[Empire of Japan|Japan]], including the Holocaust, were wartime propaganda that had been used to justify the United States' involvement in World War II. Barnes claimed that there were two false claims made about World War II, namely that Germany started the war in 1939, and the Holocaust, which Barnes claimed did not happen.{{sfn|Lipstadt|1993|p=75}} In his 1962 pamphlet, ''Revisionism and Brainwashing'', Barnes claimed that there was a "lack of any serious opposition or concerted challenge to the atrocity stories and other modes of defamation of German national character and conduct".{{sfn|Lipstadt|1993|pp=73-74}} Barnes argued that there was "a failure to point out the atrocities of the Allies were more brutal, painful, mortal and numerous than the most extreme allegations made against the Germans".{{sfn|Lipstadt|1993|p=74}} He claimed that in order to justify the "horrors and evils of the Second World War", the Allies made the Nazis the "scapegoat" for their own misdeeds.{{sfn|Lipstadt|1993|p=75}} Barnes cited the French Holocaust denier [[Paul Rassinier]], whom Barnes called a "distinguished French historian" who had exposed the "exaggerations of the atrocity stories".{{sfn|Lipstadt|1993|p=74}} In a 1964 article, "Zionist Fraud", published in the ''[[American Mercury]]'', Barnes wrote: "The courageous author [Rassinier] lays the chief blame for misrepresentation on those whom we must call the swindlers of the crematoria, the Israeli politicians who derive billions of marks from nonexistent, mythical and imaginary cadavers, whose numbers have been reckoned in an unusually distorted and dishonest manner."{{sfn|Lipstadt|1993|p=74}} Using Rassinier as his source, Barnes claimed that Germany was the victim of aggression in both 1914 and 1939 and that reports of the Holocaust were propaganda to justify a war of aggression against Germany.{{sfn|Lipstadt|1993|p=74}} ===Beginnings of modern denialism=== In 1961, a protégé of Barnes, [[David Hoggan]], published {{lang|de|Der erzwungene Krieg}} (''The Forced War'') in West Germany, which claimed that Germany had been the victim of an Anglo-Polish conspiracy in 1939. Though ''Der erzwungene Krieg'' was primarily concerned with the origins of World War II, it also down-played or justified the effects of Nazi [[antisemitic]] measures in the pre-1939 period.{{sfn|Lipstadt|1993|p=71}} For example, Hoggan justified the huge one billion [[Reichsmark]] fine imposed on the entire Jewish community in Germany after the 1938 {{lang|de|[[Kristallnacht]]}} as a reasonable measure to prevent what he called "Jewish profiteering" at the expense of German insurance companies and alleged that no Jews were killed in the ''Kristallnacht'' (in fact, 91 German Jews were murdered in the {{lang|de|Kristallnacht}}).{{sfn|Lipstadt|1993|p=71}} Subsequently, Hoggan explicitly denied the Holocaust in 1969 in a book entitled ''The Myth of the Six Million'', which was published by the [[Noontide Press]], a small Los Angeles publisher specializing in antisemitic literature.<ref>{{cite book |last=Gottfired |first=Ted |title=Deniers Of The Holocaust: Who They Are, What They Do, Why They Do It |publisher=Twenty-First Century Books |date=2001 |page=29}}</ref> In 1964, [[Paul Rassinier]] published ''The Drama of the European Jews''. Rassinier was himself a concentration camp survivor (he was held in [[Buchenwald]] for having helped French Jews escape the Nazis), and modern-day deniers continue to cite his works as scholarly research that questions the accepted facts of the Holocaust. Critics argued that Rassinier did not cite evidence for his claims and ignored information that contradicted his assertions; he nevertheless remains influential in Holocaust denial circles for being one of the first deniers to propose that a vast Zionist/Allied/Soviet conspiracy faked the Holocaust, a theme that would be picked up in later years by other authors.<ref>{{cite book |first=Deborah E. |last=Lipstadt |author-link=Deborah Lipstadt |title=History on Trial |publisher=Harcourt |date=2005 |isbn=0-06-059376-8}}</ref>{{page needed|date=June 2020}} [[Austin App]], a [[La Salle University]] medieval English literature professor, is considered the first major mainstream American holocaust denier.<ref>{{cite book |last=Knight |first=Peter |title=Conspiracy Theories in American History: An Encyclopedia |volume=1 |year=2003 |publisher=[[ABC-CLIO]] |isbn=978-1576078129 |url=https://books.google.com/books?id=qMIDrggs8TsC&q=%22Austin%20App%22%20holocaust&pg=PA322 |page=322 |access-date=March 20, 2021 |archive-date=July 5, 2024 |archive-url=https://web.archive.org/web/20240705094705/https://books.google.com/books?id=qMIDrggs8TsC&q=%22Austin%20App%22%20holocaust&pg=PA322 |url-status=live}}</ref><ref name="Atkins, Stephen E. 2009 pp. 153">{{cite book |last=Atkins |first=Stephen E. |year=2009 |title=Austin J. App and Holocaust Denial. Holocaust denial as an international movement |location=Westport, CT |publisher=Praeger |pages=153–155 |isbn=978-0-313-34539-5}}</ref> App defended the Germans and Nazi Germany during World War II. He published numerous articles, letters, and books on Holocaust denial, quickly building a loyal following. App's work inspired the [[Institute for Historical Review]], a California center founded in 1978 whose sole task is the denial of the Holocaust.<ref>{{cite book |first1=Carlos C. |last1=Huerta |first2=Dafna |last2=Shiffman-Huerta |chapter=Holocaust Denial Literature: Its Place in Teaching the Holocaust |editor1-first=Rochelle L. |editor1-last=Millen |title=New Perspectives on the Holocaust: A Guide for Teachers and Scholars |publisher=[[NYU Press]] |date=1996 |isbn=0-8147-5540-2 |page=189}}</ref> The publication of [[Arthur Butz]]'s ''[[The Hoax of the Twentieth Century]]: The case against the presumed extermination of European Jewry'' in 1976 brought other similarly inclined individuals into the fold.{{sfn|Lipstadt|1993|p=125}} Butz was a tenured associate professor of electrical engineering at [[Northwestern University]]. In December 1978 and January 1979, [[Robert Faurisson]], a French professor of literature at the [[University of Lyon]], wrote two letters to ''[[Le Monde]]'' claiming that the [[gas chambers]] used by the Nazis to exterminate the Jews did not exist. A colleague of Faurisson, [[Jean-Claude Pressac]], who initially shared Faurisson's views, later became convinced of the Holocaust's evidence while investigating documents at [[Auschwitz concentration camp|Auschwitz]] in 1979. He published his conclusions along with much of the underlying evidence in his 1989 book, ''Auschwitz: Technique and operation of the gas chambers''.<ref>{{cite book |last=Pressac |first=Jean-Claude |title=Auschwitz: Technique and operation of the gas chambers |url=http://phdn.org/archives/holocaust-history.org/auschwitz/pressac/technique-and-operation/ |via=Pratique de l'Histoire et Dévoiements Négationnistes |access-date=January 31, 2006 |year=1989 |publisher=The Beate Klarsfeld Foundation |location=New York |archive-date=January 28, 2017 |archive-url=https://web.archive.org/web/20170128063557/http://phdn.org/archives/holocaust-history.org/auschwitz/pressac/technique-and-operation/ |url-status=live}}</ref> [[Henry Bienen]], the former president of Northwestern University, has described Arthur Butz's view of the Holocaust as an "embarrassment to Northwestern".<ref name="bienen">{{cite web |url=http://www.northwestern.edu/president/arthurbutz.html |title=Message from President Bienen, Northwestern University |last=Bienen |first=Henry S. |date=February 6, 2006 |publisher=[[Northwestern University]] |access-date=September 20, 2009 |archive-url= https://web.archive.org/web/20070501100921/http://www.northwestern.edu/president/arthurbutz.html |archive-date= May 1, 2007}}</ref> In 2006, sixty of Butz's colleagues from the Department of Electrical Engineering and Computer Science faculty signed a censure describing Butz's Holocaust denial as "an affront to our humanity and our standards as scholars".<ref name="tdn">{{cite news |url=http://dailynorthwestern.com/2006/02/16/archive-manual/students-faculty-oppose-butz-with-petitions/ |title=Students, faculty oppose Butz with petitions |last=Elizabeth |first=Campbell |date=February 16, 2006 |newspaper=The Daily Northwestern |access-date=May 17, 2012 |archive-date=January 16, 2014 |archive-url=https://web.archive.org/web/20140116074722/http://dailynorthwestern.com/2006/02/16/archive-manual/students-faculty-oppose-butz-with-petitions/ |url-status=live}}</ref> The letter also called for Butz to "leave our Department and our University and stop trading on our reputation for academic excellence".{{R|tdn}} ===Institute for Historical Review=== In 1978 the American [[far-right]] activist [[Willis Carto]] founded the [[Institute for Historical Review]] (IHR), an organization dedicated to publicly challenging the commonly accepted history of the Holocaust.<ref name="TooCloseForComfort">{{cite book |first1=Chip |last1=Berlet |first2=Matthew J. |last2=Lyons |title=Right-Wing Populism in America: Too Close for Comfort |location=New York |publisher=[[Guilford Press]] |date=2000 |page=189}}</ref> The IHR's founding was inspired by [[Austin App]], a [[La Salle University|La Salle]] professor of medieval English literature and considered the first major American holocaust denier.{{R|Atkins, Stephen E. 2009 pp. 153}} The IHR sought from the beginning to establish itself within the broad tradition of historical revisionism, by soliciting token supporters who were not from a [[neo-Nazi]] background such as [[James J. Martin (historian)|James J. Martin]] and [[Samuel Edward Konkin III]], and by promoting the writings of French socialist Paul Rassinier and American anti-war historian Harry Elmer Barnes, in an attempt to show that Holocaust denial had a base of support beyond neo-Nazis. The IHR republished most of Barnes's writings, which had been out of print since his death. While it included articles on other topics and sold books by mainstream historians, the majority of material published and distributed by IHR was devoted to questioning the facts surrounding the Holocaust.<ref>{{cite book |first=Richard J. |last=Evans |title=Lying About Hitler: History, Holocaust, and the David Irving Trial |publisher=[[Basic Books]] |date=2002 |isbn=0-465-02153-0}}</ref>{{page needed|date=June 2020}} In 1980, the IHR promised a $50,000 reward to anyone who could prove that Jews were gassed at Auschwitz. [[Mel Mermelstein]] wrote a [[letter to the editor]]s of the ''[[Los Angeles Times]]'' and others including ''[[The Jerusalem Post]]''. The IHR wrote back, offering him $50,000 for proof that Jews were, in fact, gassed in the gas chambers at Auschwitz. Mermelstein, in turn, submitted a notarized account of his internment at Auschwitz and how he witnessed Nazi guards ushering his mother and two sisters and others towards (as he learned later) gas chamber number five. Despite this, the IHR refused to pay the reward. Represented by public interest attorney [[William John Cox]], Mermelstein subsequently sued the IHR in the [[Superior Court of Los Angeles County]] for [[breach of contract]], [[anticipatory repudiation]], [[libel]], [[injurious denial of established fact]], [[intentional infliction of emotional distress]], and [[declaratory relief]]. On October 9, 1981, both parties in the Mermelstein case filed motions for [[summary judgment]] in consideration of which Judge Thomas T. Johnson of the [[Superior Court of Los Angeles County]] took "[[judicial notice]] of the fact that Jews were gassed to death at the Auschwitz Concentration Camp in Poland during the summer of 1944,"<ref name="NYT">{{cite news |title=California Judge Rules Holocaust Did Happen |date=October 10, 1981 |page=A26 |newspaper=[[The New York Times]] |agency=[[Associated Press]] |url=https://www.nytimes.com/1981/10/10/us/california-judge-rules-holocaust-did-happen.html |access-date=November 20, 2010 |archive-date=October 19, 2018 |archive-url=https://web.archive.org/web/20181019142015/https://www.nytimes.com/1981/10/10/us/california-judge-rules-holocaust-did-happen.html |url-status=live}}</ref><ref name="order">{{cite web |url=http://www.nizkor.org/ftp.cgi/people/m/mermelstein.mel/ftp.py?people/m/mermelstein.mel//mermelstein.order.072285 |title=Mel Mermelstein v. Institute for Historical Review Judgment and Statement of Record |access-date=November 20, 2010 |archive-url=https://web.archive.org/web/20110717102709/http://www.nizkor.org/ftp.cgi/people/m/mermelstein.mel/ftp.py?people%2Fm%2Fmermelstein.mel%2F%2Fmermelstein.order.072285 |archive-date=July 17, 2011 |url-status=dead}}</ref> judicial notice meaning that the court treated the gas chambers as common knowledge, and therefore did not require evidence that the gas chambers existed. On August 5, 1985, Judge Robert A. Wenke entered a judgment based upon the [[Stipulation]] for Entry of Judgment agreed upon by the parties on July 22, 1985. The judgment required IHR and other defendants to pay $90,000 to Mermelstein and to issue a letter of apology to "Mr. Mel Mermelstein, a [[Holocaust survivors|survivor]] of Auschwitz-Birkenau and Buchenwald, and all other survivors of Auschwitz" for "pain, anguish and suffering" caused to them.{{R|order}} In the "About the IHR" statement on their website, the IHR states, "The IHR does not 'deny' the Holocaust. Indeed, the IHR as such has no 'position' on any specific event...."<ref>{{cite web |url=http://ihr.org/main/about.shtml|title=About the IHR: Our Mission and Record |date=May 2018 |work=Institute for Historical Review |access-date=July 9, 2011 |archive-url=https://web.archive.org/web/20071013154000/http://ihr.org/main/about.shtml |archive-date=October 13, 2007 |url-status=dead}}</ref> British historian [[Richard J. Evans]] wrote that the Institute's acknowledgment "that a relatively small number of Jews were killed" was a means to draw attention away from its primary beliefs, i.e. that the number of victims was not in the millions and that Jews were not systematically murdered in gas chambers.<ref>[[Richard J. Evans]]. ''Telling Lies About Hitler: The Holocaust, History and the David Irving Trial'', [[Verso Books]], 2002, {{ISBN|1-85984-417-0}}, p. 151. Quote: Like many individual Holocaust deniers, the Institute as a body denied that it was involved in Holocaust denial. It called this a 'smear' which was 'completely at variance with the facts' because 'revisionist scholars' such as Faurisson, Butz 'and bestselling British historian David Irving acknowledge that hundreds of thousands of Jews were killed and otherwise perished during the Second World War as a direct and indirect result of the harsh anti-Jewish policies of Germany and its allies'. But the concession that a relatively small number of Jews were killed was routinely used by Holocaust deniers to distract attention from the far more important fact of their refusal to admit that the figure ran into the millions, and that a large proportion of these victims were systematically murdered by gassing as well as by shooting.</ref> ===James Keegstra=== {{Further|R. v. Keegstra}} In 1984, [[James Keegstra]], a Canadian high-school teacher, was charged under the Canadian [[Criminal Code (Canada)|''Criminal Code'']] for "promoting hatred against an identifiable group by communicating anti-Semitic statements to his students". During class, he would describe Jews as a people of profound evil who had "created the Holocaust to gain sympathy." He also tested his students in exams on his theories and opinion of Jews.<ref>{{cite book |last1=Elman |first1=Bruce P. |editor1-last=DeCoste |editor1-first=F. C. |editor2-last=Schwartz |editor2-first=Bernard |title=The Holocaust's Ghost: Writings on Art, Politics, Law and Education |date=2000 |publisher=[[University of Alberta Press]] |isbn=978-0-88864-337-7 |page=316 |chapter-url=https://books.google.com/books?id=lLnBSq7YP0gC&pg=PA316 |language=en |chapter=The Belzberg Lecture: Honouring Memory, Doing Justice: Holocaust Denial, Hate Propaganda and Canadian Law |access-date=March 4, 2022 |archive-date=July 5, 2024 |archive-url=https://web.archive.org/web/20240705094705/https://books.google.com/books?id=lLnBSq7YP0gC&pg=PA316#v=onepage&q&f=false |url-status=live}}</ref> Keegstra was charged under s 281.2(2) of the ''Criminal Code''{{citation needed|date=June 2020}} (now s 319(2)), which provides that "Every one who, by communicating statements, other than in private conversation, wilfully promotes hatred against any identifiable group" commits a criminal offense.<ref>''Criminal Code'', RSC 1970, c C-34, s 281.2(2); now ''Criminal Code'', RSC 1985, c C-46, s 319(2).</ref> He was convicted at trial before the [[Alberta Court of Queen's Bench]]. The court rejected the argument, advanced by Keegstra and his lawyer, [[Doug Christie (lawyer)|Doug Christie]], that promoting hatred is a constitutionally protected freedom of expression as per [[Section Two of the Canadian Charter of Rights and Freedoms|s 2(b) of the Canadian Charter of Rights and Freedoms]]. Keegstra appealed to the [[Alberta Court of Appeal]]. That court agreed with Keegstra, and he was acquitted. The Crown then appealed the case to the [[Supreme Court of Canada]], which ruled by a 4–3 majority that promoting hatred could be [[R. v. Keegstra#Reasons of the court|justifiably]] restricted under [[Section One of the Canadian Charter of Rights and Freedoms|s 1 of the Charter]]. The Supreme Court restored Keegstra's conviction.<ref>{{cite web |url=https://scc-csc.lexum.com/scc-csc/scc-csc/en/item/695/index.do|title=R. v. Keegstra – SCC Cases (Lexum) |website=scc-csc.lexum.com |date=January 2001 |access-date=February 24, 2019 |archive-date=July 10, 2019 |archive-url=https://web.archive.org/web/20190710021813/https://scc-csc.lexum.com/scc-csc/scc-csc/en/item/695/index.do |url-status=live}}</ref> He was fired from his teaching position shortly afterward.<ref>*"The trouble erupted when the teacher's anti-Jewish (and, incidentally, anti-Catholic) views attracted complaints from certain Eckville parents, thereby inviting intervention from the district school superintendent, Robert David, in 1981. A train of events was launched that finally led to Keegstra's dismissal and subsequent indictment." Alan Davies, "The Keegstra Affair", in Alan T. Davies, ''Antisemitism in Canada: History and Interpretation'', Wilfrid Laurier University Press, 1992, {{ISBN|0-88920-216-8}}, p. 228. *"Far from arguing that Keegstra had a civil right to continue spreading his dreck at Eckville High, civil libertarians wonder (along with the rest of Canada, we hope) why it took twelve years for the local school board to exercise its appropriate authority and fire him. But at least Keegstra was finally fired, and was finally removed from his position as Mayor of Eckville." John Dixon, [http://www.bccla.org/positions/freespeech/85keegstra.html The Keegstra case: Freedom of speech and the prosecution of harmful ideas] {{webarchive|url=https://web.archive.org/web/20070926232724/http://www.bccla.org/positions/freespeech/85keegstra.html |date=September 26, 2007 }}, [[British Columbia Civil Liberties Association]] Position Paper, 1986. Retrieved June 27, 2007.</ref> ===Zündel trials=== {{See also|Leuchter report}} The Toronto-based photo retoucher [[Ernst Zündel]] operated a small-press called [[Samisdat Publishers]], which published and distributed Holocaust-denial material such as ''[[Did Six Million Really Die?]]'' by Richard Harwood (a pseudonym of [[Richard Verrall (political writer)|Richard Verrall]] – a British neo-Nazi). In 1985, he was tried in ''[[R. v. Zundel]]'' and convicted under a "false news" law and sentenced to 15 months imprisonment by an [[Ontario]] court for "disseminating and publishing material denying the Holocaust".<ref name="Zundelcourt">{{cite court |litigants=R. v. Zundel |vol= |reporter= |opinion= |pinpoint= |court= |date=August 27, 1992 |url=http://scc.lexum.umontreal.ca/en/1992/1992rcs2-731/1992rcs2-731.html |archive-url=https://web.archive.org/web/20071012161758/http://scc.lexum.umontreal.ca/en/1992/1992rcs2-731/1992rcs2-731.html |url-status=dead}}</ref> The Holocaust historian [[Raul Hilberg]] was a witness for the prosecution at the 1985 trial. Zündel's conviction was overturned in an appeal on a legal technicality, leading to a second trial in 1988, in which he was again convicted. The 1988 trial included, as witnesses for the defense, [[Fred A. Leuchter]], [[David Irving]] and [[Robert Faurisson]]. The pseudo-scientific [[Leuchter report]] was presented as a defense document and was published in Canada in 1988 by Zundel's Samisdat Publishers, and in Britain in 1989 by Irving's Focal Point Publishing. In both of his trials, Zündel was defended by [[Doug Christie (lawyer)|Douglas Christie]] and [[Barbara Kulaszka]]. His conviction was overturned in 1992 when the Supreme Court of Canada declared the "false news" law unconstitutional.{{R|Zundelcourt}} Zündel had a website, web-mastered by his wife Ingrid, which publicized his viewpoints.<ref>{{cite web |url=http://www.zundelsite.org/ |title=Zundelsite |website=www.zundelsite.org |access-date=June 27, 2007 |archive-date=December 21, 2021 |archive-url=https://web.archive.org/web/20211221092253/http://www.zundelsite.org/ |url-status=live}}{{title missing|date=May 2022}}</ref> In January 2002, the [[Canadian Human Rights Commission|Canadian Human Rights Tribunal]] delivered a ruling in a complaint involving his website, in which it was found to be contravening the [[Canadian Human Rights Act]]. The court ordered Zündel to cease communicating hate messages. In February 2003, the American [[Immigration and Naturalization Service|INS]] arrested him in [[Tennessee]], US, on an immigration violations matter, and few days later, Zündel was sent back to Canada, where he tried to gain refugee status. Zündel remained in prison until March 1, 2005, when he was deported to Germany and prosecuted for disseminating hate propaganda. On February 15, 2007, Zündel was convicted on 14 counts of incitement under Germany's ''[[Volksverhetzung]]'' law, which bans the incitement of hatred against a portion of the population and given the maximum sentence of five years in prison.<ref>{{cite web |url=http://www.canada.com/topics/news/world/story.html?id=c61ce061-50b2-42a5-bb2f-a7bbaecccceb&k=32537 |title=German court sentences Ernst Zundel to 5 years in prison for Holocaust denial |agency=The Canadian Press |publisher=canada.com|date=February 15, 2007 |access-date=February 15, 2007 |url-status=dead |archive-url=https://web.archive.org/web/20070929104434/http://www.canada.com/topics/news/world/story.html?id=c61ce061-50b2-42a5-bb2f-a7bbaecccceb&k=32537 |archive-date=September 29, 2007}}</ref> ===Bradley Smith and the CODOH=== In 1987, Bradley R. Smith, a former media director of the Institute for Historical Review,<ref>{{cite web|url=http://www.axt.org.uk/antisem/archive/archive2/usa/usa.htm|title=United States of America|date=1998|work=axt.org.uk|url-status=dead|archive-url=https://web.archive.org/web/20080620114155/http://www.axt.org.uk/antisem/archive/archive2/usa/usa.htm|archive-date=June 20, 2008}}</ref> founded the Committee for Open Debate on the Holocaust (CODOH).<ref>[http://www.adl.org/poisoning_web/codoh.asp "Poisoning the Web – Committee for Open Debate on the Holocaust."] {{Webarchive|url=https://web.archive.org/web/20130115233738/http://www.adl.org/poisoning_web/codoh.asp |date=January 15, 2013 }} ''[[Anti-Defamation League|ADL]]''. 2001. April 24, 2008.</ref> In the United States, CODOH has repeatedly attempted to place advertisements questioning whether the Holocaust happened, especially in college campus newspapers.<ref>[http://www.adl.org/holocaust/bradley_smith.asp "Bradley Smith and the Committee for Open Debate on the Holocaust: The New College Try".] {{Webarchive|url=https://web.archive.org/web/20130115233745/http://www.adl.org/holocaust/bradley_smith.asp |date=January 15, 2013 }} ''[[Anti-Defamation League|ADL]]''. 2001. April 24, 2008.</ref> Bradley Smith took his message to college students—with little success. Smith referred to his tactics as the CODOH campus project. He said, "I don't want to spend time with adults anymore, I want to go to students. They are superficial. They are empty vessels to be filled." "What I wanted to do was I wanted to set forth three or four ideas that students might be interested in, that might cause them to think about things or to have questions about things. And I wanted to make it as simple as possible, and to set it up in a way that could not really be debated."<ref>{{cite web |url=http://www.adl.org/learn/ext_us/smith_codoh/words.asp?LEARN_Cat=Extremism&LEARN_SubCat=Extremism_in_America&xpicked=2&item=10 |title=Bradley Smith, Holocaust Denial, Committee for Open Debate on the Holocaust – Extremism in America |publisher=[[Anti-Defamation League]] |access-date=March 26, 2013 |archive-date=January 15, 2013 |archive-url=https://web.archive.org/web/20130115233646/http://www.adl.org/learn/ext_us/smith_codoh/words.asp?LEARN_Cat=Extremism&LEARN_SubCat=Extremism_in_America&xpicked=2&item=10 |url-status=live}}</ref> Holocaust deniers have placed "Full page advertisements in college and university newspapers, including those of [[Brandeis University]], [[Boston College]], [[Pennsylvania State University]], and [[Queens College]]. Some of these ads arguing that the Holocaust never happened ran without comment; others generated op-ed pieces by professors and students".<ref>{{cite book |last=Shermar |first=Michael |author2=Alex Grobman |title=Denying History: Who Says the Holocaust Never Happened and Why Do They Say It? |publisher=[[University of California Press]] |year=2000 |isbn=978-0-520-21612-9 |title-link=Denying History: Who Says the Holocaust Never Happened and Why Do They Say It?}}</ref> On September 8, 2009, student newspaper ''[[The Harvard Crimson]]'' ran a paid ad from Bradley R Smith. It was quickly criticized, and the editor issued an apology, saying publishing the ad was a mistake.<ref>{{Cite news |url=http://edition.cnn.com/2009/US/09/09/massachusetts.harvard.holocaust/index.html |title=Harvard Crimson says Holocaust denial ad published by accident |last=Buxbaum |first=Evan |date=September 10, 2009 |work=[[CNN]] |access-date=September 10, 2009 |archive-date=May 12, 2019 |archive-url=https://web.archive.org/web/20190512200839/http://edition.cnn.com/2009/US/09/09/massachusetts.harvard.holocaust/index.html |url-status=live}}</ref><!-- For the whole paragraph as it falls under [[Wikipedia: Biographies of living persons]]--> ===Ernst Nolte=== The German philosopher and historian [[Ernst Nolte]], starting in the 1980s, advanced a set of theories, which though not denying the Holocaust appeared to flirt with an Italian Holocaust denier, [[Carlo Mattogno]], as a serious historian.<ref name="Evans, Richard J. page 83">{{cite book |last=Evans |first=Richard J. |author-link=Richard J. Evans |title=In Hitler's Shadow |location=New York |publisher=[[Pantheon Books]] |date=1989 |page=83}}</ref> In a letter to the Israeli historian [[Otto Dov Kulka]] of December 8, 1986, Nolte criticized the work of the French Holocaust denier [[Robert Faurisson]] on the ground that the Holocaust did occur, but went on to argue that Faurisson's work was motivated by what Nolte claimed were the admirable motives of sympathy towards the Palestinians and opposition to Israel.<ref>Maier, Charles ''The Unmasterable Past'', Cambridge: Harvard University Press, 1988 page 190.</ref> In his 1987 book {{lang|de|Der europäische Bürgerkrieg}} (''The European Civil War''), Nolte claimed that the intentions of Holocaust deniers are "often honourable", and that some of their claims are "not obviously without foundation".{{R|Evans, Richard J. page 83}}<ref name=LipstadtDenying214>Lipstadt, Deborah ''Denying the Holocaust'', New York: Free Press, 1993 page 214</ref> Nolte himself, though he has never denied the occurrence of the Holocaust, has claimed that the [[Wannsee Conference]] of 1942 never happened and that the minutes of the conference were post-war forgeries done by "biased" Jewish historians designed to discredit Germany.{{R|LipstadtDenying214}} The British historian [[Ian Kershaw]] has argued that Nolte was operating on the borderlines of Holocaust denial with his implied claim that the "negative myth" of Nazi Germany was created by Jewish historians, his allegations of the domination of Holocaust scholarship by "biased" Jewish historians, and his statements that one should withhold judgment on Holocaust deniers, whom Nolte takes considerable pains to stress are not exclusively Germans or fascists.<ref name="Kershaw, Ian page 176">Kershaw, Ian ''The Nazi Dictatorship: Problems and Perspectives of Interpretations'', London: Arnold, 1989 page 176</ref> In Kershaw's opinion, Nolte is attempting to imply that perhaps Holocaust deniers are on to something.{{R|Kershaw, Ian page 176}} In a 1990 interview, Nolte implied that there was something to the [[Leuchter report]]: "If the revisionists [Holocaust deniers] and Leuchter among them have made it clear to the public that even 'Auschwitz' must be an object of scientific inquiry and controversy then they should be given credit for this. Even if it finally turned out that the number of victims was even greater and the procedures were even more horrific than has been assumed until now."<ref>{{cite book |last=Brinks |first=Jan Hermann |title=Children of a New Fatherland |location=London |publisher=[[I. B. Tauris]] |date=2000 |page=108}}</ref> In his 1993 book {{lang|de|Streitpunkte}} (''Points of Contention''), Nolte praised the work of Holocaust deniers as superior to "mainstream scholars".<ref name="Wistrich, Robert S pages 293-301">Wistrich, Robert S. "Holocaust Denial" pages 293–301 from ''The Holocaust Encyclopedia'' edited by Walter Laqueur, New Haven: Yale University Press, 2001 page 299</ref> Nolte wrote that "radical revisionists have presented research which, if one is familiar with the source material and the critique of the sources, is probably superior to that of the established historians of Germany".{{R|Wistrich, Robert S pages 293-301}}<ref>Lukacs, John ''The Hitler of History'' New York: Vintage Books, 1997, 1998 page 233.</ref> In a 1994 interview with {{lang|de|[[Der Spiegel]]}} magazine, Nolte stated "I cannot rule out the importance of the investigation of the gas chambers in which they looked for remnants of the [chemical process engendered by Zyklon B]", and that "'Of course, I am against revisionists, but Fred Leuchter's 'study' of the Nazi gas ovens has to be given attention because one has to stay open to 'other' ideas."<ref>{{cite web |last=Charny |first=Israel |author-link=Israel Charny |title=The Psychological Satisfaction of Denials of the Holocaust or Other Genocides by Non-Extremists or Bigots, and Even by Known Scholars |publisher=Idea Journal |date=July 17, 2001 |url=http://www.ideajournal.com/articles.php?id=27 |access-date=August 7, 2015 |archive-url=https://web.archive.org/web/20071224203627/http://www.ideajournal.com/articles.php?id=27 |archive-date=December 24, 2007 |url-status=dead}}</ref> The British historian [[Richard J. Evans]] in his 1989 book ''In Hitler's Shadow'' expressed the view that Nolte's reputation as a scholar was in ruins as a result of these and other controversial statements on his part.<ref>Evans, Richard ''In Hitler's Shadow'', New York, NY: Pantheon, 1989 page 123</ref> The American historian [[Deborah Lipstadt]] in a 2003 interview stated: {{blockquote|Historians such as the German Ernst Nolte are, in some ways, even more dangerous than the deniers. Nolte is an anti-Semite of the first order, who attempts to rehabilitate Hitler by saying that he was no worse than Stalin; but he is careful not to deny the Holocaust. Holocaust-deniers make Nolte's life more comfortable. They have, with their radical argumentation, pulled the center a little more to their side. Consequently, a less radical extremist, such as Nolte, finds himself closer to the middle ground, which makes him more dangerous.<ref>{{cite web |last=Gerstenfeld |first=Manfred |title=Denial of the Holocaust and Immoral Equivalence An Interview with Deborah Lipstadt |publisher=Jerusalem Centre for Public Affairs |date=August 1, 2003 |url=http://www.jcpa.org/phas/phas-11.htm |access-date=June 21, 2007 |archive-date=August 16, 2007 |archive-url=https://web.archive.org/web/20070816010915/http://www.jcpa.org/phas/phas-11.htm |url-status=live}}</ref>}} ===Mayer controversy=== In 1988, the American historian [[Arno J. Mayer]] published a book entitled ''Why Did the Heavens Not Darken?'', which did not explicitly deny the Holocaust, but according to [[Lucy Dawidowicz]] lent support to Holocaust denial by stating that most people who died at [[Auschwitz concentration camp|Auschwitz]] were the victims of "natural causes" such as disease, not gassing.<ref>Dawidowicz, Lucy ''What Is The Use of Jewish History?'', New York: Schocken Books, 1992 pages 129–130</ref> Dawidowicz argued that Mayer's statements about Auschwitz were "a breathtaking assertion".<ref>Dawidowicz, Lucy ''What Is The Use of Jewish History?'', New York: Schocken Books, 1992 page 130</ref> Holocaust historian [[Robert Jan van Pelt]] has written that Mayer's book is as close as a mainstream historian has ever come to supporting Holocaust denial.<ref name="Pelt pages 47-48">Pelt, Robert Jan van ''The Case for Auschwitz'', Bloomington: Indiana University Press, 2002 pages 47–48</ref> Holocaust deniers such as [[David Irving]] have often cited Mayer's book as one reason for embracing Holocaust denial.{{R|Pelt pages 47-48}} Though Mayer has been often condemned for his statement about the reasons for the Auschwitz death toll, his book does not deny the use of gas chambers at Auschwitz, as Holocaust deniers often claim.<ref>{{cite news |last=Stein |first=Michael |title=The Mayer Gambit |newspaper=Nizkor Project |date=October 2, 2008 |url=http://www.nizkor.org/features/techniques-of-denial/mayer-01.html |access-date=June 4, 2009 |archive-url=https://web.archive.org/web/20090502170033/http://www.nizkor.org/features/techniques-of-denial/mayer-01.html |archive-date=May 2, 2009 |url-status=dead}}</ref> Some mainstream Holocaust historians have labeled Mayer a denier. The Israeli historian [[Yehuda Bauer]] wrote that Mayer "popularizes the nonsense that the Nazis saw in Marxism and Bolshevism their main enemy, and the Jews unfortunately got caught up in this; when he links the destruction of the Jews to the ups and downs of German warfare in the Soviet Union, in a book that is so cocksure of itself that it does not need a proper scientific apparatus, he is really engaging in a much more subtle form of Holocaust denial".<ref>Bauer, Yehuda "A Past That Will Not Away" pages 12–22 from ''The Holocaust and History'' edited by Michael Berenbaum and Abrahm Peck, Bloomington: [[Indiana University Press]], 1998 page 15.</ref> Defenders of Mayer argue that his statement that "Sources for the study of the gas chambers are at once rare and unreliable" has been taken out of context, particularly by Holocaust deniers.<ref>Shermer, Michael & Grobman, Alex ''Denying History: Who Says the Holocaust Never Happened and Why Do They Say It?'', Berkeley: University of California Press, 2002 page 126.</ref> [[Michael Shermer]] and [[Alex Grobman]] observe that the paragraph from which the statement is taken asserts that the SS destroyed the majority of the documentation relating to the operation of the gas chambers in the death camps, which is why Mayer feels that sources for the operation of the gas chambers are "rare" and "unreliable".<ref>Shermer, Michael & Grobman, Alex ''Denying History: Who Says the Holocaust Never Happened and Why Do They Say It?'', Berkeley: University of California Press, 2002 pages 126–127.</ref>
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