District Court, W.D. Pennsylvania June 26, 1984, Civ. A. 82-1939 (Mellon Bank, NA v. United States)

MEMORANDUM

McCUNE, District Judge.

The issue before us on cross motions for summary judgment is whether or not the Verona Cemetery, a non-profit corporation, is a “corporation organized and operated exclusively for ... charitable ... purposes,” under § 2055(a)(2) of the Internal Revenue Code of 1954, as amended.

The plaintiffs have exhausted' their administrative remedies.