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BILINGUAL MONTESSORI SCHOOL OF PARIS, INC. v. COMMISSIONER

Docket No. 16172-79X.

75 T.C. 480 (1980)

BILINGUAL MONTESSORI SCHOOL OF PARIS, INC., A DELAWARE CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 30, 1980.

Attorney(s) appearing for the Case

Michael A. Friedberg, for the petitioner.

John W. Schmehl, for the respondent.

OPINION

EKMAN, Judge:

This is an action for declaratory relief brought by Bilingual Montessori School of Paris, Inc. (hereinafter petitioner), against respondent under section 7428 of the Internal Revenue Code of 1954. The statutory prerequisites for declaratory judgment have been satisfied. The only issue before the Court is whether petitioner is an organization described in section 170(c)(2)(A) so that contributions to petitioner will be deductible...

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