ON PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT AND DEFENDANT'S CROSS-MOTION FOR SUMMARY JUDGMENT
NICHOLS, Judge:
Plaintiff Northern California Central Services (NCCS), a shared laundry service organization, seeks a declaratory judgment under 26 U.S.C. § 7428(a)(1) that it is a "charitable organization" as defined in § 501(c)(3) of the Internal Revenue Code, and thus entitled to an exemption from federal income tax under § 501(a).
Northern...
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