MEMORANDUM AND ORDER
MORAN, District Judge.
The Internal Revenue Service terminated plaintiff's status as a tax-exempt private foundation, as defined in the Internal Revenue Code, 26 U.S.C. § 501(c)(3), while simultaneously placing upon it a $30,000,000 jeopardy assessment. Section 507(a)(2) directs the IRS to terminate a private foundation's § 501(c)(3) status for wilful, repeated or flagrant acts giving rise to tax liability under chapter 42...
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