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AMERICAN GUIDANCE FOUNDATION v. UNITED STATES

Civ. A. No. 79-2061.

490 F.Supp. 304 (1980)

AMERICAN GUIDANCE FOUNDATION, INC., Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, District of Columbia.

May 22, 1980.

Attorney(s) appearing for the Case

Lee T. Ellis, Jr., Washington, D. C., for plaintiff.

Patricia A. Scott, Dept. of Justice, Washington, D. C., for defendant.

MEMORANDUM AND ORDER

GESELL, District Judge.

Plaintiff, American Guidance Foundation, Inc. ("AGF"), a non-stock non-profit corporation operating in Philadelphia, seeks to be declared a "church" for tax purposes. After four years of administrative controversy, the Internal Revenue Service ("IRS") rejected AGF's request, leaving it classified as a private foundation, see 26 U.S.C. § 509(a) (1976), but not as a church, see 26 U.S.C. §...

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