MEMORANDUM OPINION AND ORDER
CONLON, District Judge.
The parties have submitted cross-motions for summary judgment that are dispositive of plaintiff's entire claim for tax refunds. For the following reasons, the court grants defendant's motion.
Facts
The facts are not in dispute. Plaintiff is a tax-exempt organization under Sections 501(a) and 501(c)(3) of the Internal Revenue Code of 1954, as amended ("Code"), 26 U.S.C. § 1...
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