CUMMINGS, Circuit Judge.
Plaintiff Educo, Inc., is a corporation which has engaged in the business of designing, implementing and administrating educational benefit plans for corporate employees for over a decade. On September 2, 1975, defendant Commissioner of Internal Revenue issued Technical Information Release (TIR) 1406, subsequently republished as Revenue Ruling 75-448 (1975-2 C.B. 55), which significantly changed the tax status of the transactions involved...
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