MEMORANDUM OPINION
REGGIE B. WALTON, District Judge.
The plaintiff, Educational Assistance Foundation for the Descendants of Hungarian Immigrants in the Performing Arts, Inc. ("Foundation"), brings this action under 26 U.S.C. § 7428 (2006) against the United States for a declaratory judgment finding that the Foundation is a tax-exempt organization under 26 U.S.C. § 501(c)(3) (Supp.2011). Following the submission of the parties' Joint Report, the...
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