OPINION
WILLIAM M. TAYLOR, Chief Judge.
This is a suit to recover taxes paid under protest, predicated on the refusal of an allowance of an exemption under § 501(c)(13) of the Internal Revenue Code of 1954.
Mr. George Young acquired a part ownership in the for-profit predecessor cemetery of Plaintiff cemetery in 1935. In 1941, he became in essence the sole owner of the predecessor corporation. In 1954, he organized Plaintiff as a non-profit...
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