District Court, District of Columbia April 18, 1979, Civ. A. 78-1103 (Prince Edward School Foundation v. Commissioner of Internal Revenue Service)

MEMORANDUM OPINION

JOHN H. PRATT, District Judge.

This is a suit for declaratory judgment pursuant to section 7428 of the Internal Revenue Code as amended by section 1306(a) of the Tax Reform Act of 1976, 90

*109

Stat. 1717.

1

Plaintiff seeks a ruling declaring that it is a tax-exempt organization described in section 501(c)(3) of the Internal Revenue Code of 1954.