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RANCHO SANTA FE ASS'N v. UNITED STATES

Civ. No. 83-0547-E(I).

589 F.Supp. 54 (1984)

RANCHO SANTA FE ASSOCIATION, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, S.D. California.

January 31, 1984.

Attorney(s) appearing for the Case

David R. Clark, Aylward, Kintz, Stiska, Wassenaar & Shannahan, San Diego, Cal., for plaintiff.

Nancy Morgan, Trial Atty., Tax Div., U.S. Dept. of Justice, Washington, D.C., for defendant.

MEMORANDUM DECISION

ENRIGHT, District Judge.

This is an action for refund of federal income taxes paid under protest in the amount of $313,927.00 by plaintiff Rancho Santa Fe Association, Inc. (hereinafter referred to as "Association"). Plaintiff seeks a refund of this amount as well as a declaration of plaintiff's tax exempt status under Section 501(c)(4) of the Internal Revenue Code of 1954, 26 U.S.C. § 501(c)(4) (1976). The Section 501(c)(4) exemption...

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