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BIG MAMA RAG, INC. v. UNITED STATES

Civ. A. No. 77-1649.

494 F.Supp. 473 (1979)

The BIG MAMA RAG, INC., Plaintiff, v. The UNITED STATES of America, W. Michael Blumenthal, as Secretary of the Treasury, and Jerome Kurtz, as Commissioner of the Internal Revenue Service, Defendants.

United States District Court, District of Columbia.

April 30, 1979.

Attorney(s) appearing for the Case

Jeffery L. Yablon, Covington & Burling, Washington, D. C., for plaintiff.

Michael J. Kearns, Trial Atty., Tax Div., Dept. of Justice, Washington, D. C., for defendants.

MEMORANDUM

SIRICA, District Judge.

The sole issue before the Court for review in this case is whether or not plaintiff Big Mama Rag, Inc. (BMR), qualifies as a tax-exempt organization under the terms of 26 U.S.C. § 501(c)(3) (1976). Plaintiff seeks a declaration of its tax-exempt status under the provisions of 26 U.S.C. § 7428 (1976), a recently enacted statute which provides for determination of the tax-exempt status vel non of an organization...

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