RULING ON CROSS-MOTIONS FOR SUMMARY JUDGMENT
EGINTON, District Judge.
The plaintiff, Balso Foundation ("Balso"), brings this suit as a taxpayer seeking a refund of taxes paid. Balso and the United States agree on the facts as set forth below and both have moved for summary judgment.
In late 1971, the Ball and Socket Manufacturing Co. ("Ball and Socket") established Balso as a private foundation exempt from taxation by 26 U.S.C. § 501(a). Balso...
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