United States Court of Federal Claims April 24, 2006, No. 99-197T (New Dynamics Foundation v. United States)

OPINION

ALLEGRA, Judge.

“[Cjharity begins at home, and justice begins next door.”1

New Dynamics Foundation (plaintiff or NDF) brings this declaratory judgment action under 26 U.S.C. § 7428(a), seeking a declaration that it is exempt from taxation under sections 501(a) and 501(c)(3) of the Internal Revenue Code of 1986 (the Code).