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SYNANON CHURCH v. UNITED STATES

Civ. A. No. 82-2303.

579 F.Supp. 967 (1984)

The SYNANON CHURCH, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, District of Columbia.

As Corrected March 8, 1984.

Attorney(s) appearing for the Case

Philip C. Bourdette of Bourdette, Benjamin & Weill, Washington, D.C., and Geoffrey P. Gitner of Scherr, Krebs & Gitner, Washington, D.C., for plaintiff.

Thomas M. Lawler and Francis G. Hertz, U.S. Dept. of Justice, Tax Div., Washington, D.C., for defendant. Of counsel to defendant: Stanley S. Harris, and his successor, Joseph E. DiGenova, U.S. Attys., Washington, D.C., for the District of Columbia.

CHARLES R. RICHEY, District Judge.

INTRODUCTION

Synanon filed a complaint for declaratory relief in August 1982, pursuant to the Internal Revenue Code of 1954, 26 U.S.C. § 7428, alleging, inter alia, that the Internal Revenue Service ("IRS") erroneously revoked its tax-exempt status under § 501(c)(3) for the two fiscal years ending August 31, 1977, and August 31, 1978.1

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