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PRINCE EDWARD SCH. FOUNDATION v. C. I. R.

Civ. A. No. 78-1103.

478 F.Supp. 107 (1979)

PRINCE EDWARD SCHOOL FOUNDATION, Plaintiff, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Defendant.

United States District Court, District of Columbia.

April 18, 1979.

Attorney(s) appearing for the Case

George S. Leonard, Alexandria, Va., for plaintiff.

Thomas M. Lawler, Jr., Tax Div., U. S. Dept. of Justice, Washington, D. C., for defendant.

MEMORANDUM OPINION

JOHN H. PRATT, District Judge.

This is a suit for declaratory judgment pursuant to section 7428 of the Internal Revenue Code as amended by section 1306(a) of the Tax Reform Act of 1976, 90 Stat. 1717.1 Plaintiff seeks a ruling declaring that it is a tax-exempt organization described in section 501(c)(3) of the Internal Revenue Code of 1954. Defendant, in opposition...

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