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CHANGE-ALL SOULS HOUSING CORP. v. UNITED STATES

No. 56-79.

671 F.2d 463 (1982)

CHANGE-ALL SOULS HOUSING CORPORATION v. The UNITED STATES.

United States Court of Claims.

February 10, 1982.

Attorney(s) appearing for the Case

John P. Manwell, Washington, D. C., attorney of record, for plaintiff; Kirkland & Ellis, Washington, D. C., of counsel.

Kevin B. Shea, with whom was Asst. Atty. Gen. M. Carr Ferguson, Washington, D. C., for defendant; Theodore D. Peyser and Robert S. Watkins, Washington, D. C., of counsel.

Before FRIEDMAN, Chief Judge, COWEN, Senior Judge, and NICHOLS, Judge.

ON CROSS-MOTIONS FOR SUMMARY JUDGMENT

FRIEDMAN, Chief Judge, delivered the opinion of the court:

The issue in this case is whether the plaintiff is a private foundation under section 509(a) of the Internal Revenue Code of 1954, 26 U.S.C. § 509(a) (1976). The plaintiff seeks a declaratory judgment under 26 U.S.C. § 7428 that it is not such a foundation. We agree.

I.

Before discussing the facts of this case, it is helpful to describe...

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