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VIRGINIA EDUC. FUND v. C.I.R.

No. 85-2296.

799 F.2d 903 (1986)

VIRGINIA EDUCATION FUND, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Fourth Circuit.

Decided August 20, 1986.

Attorney(s) appearing for the Case

John W. Pearsall (McCaul, Grigsby, Pearsall, Manning & Davis, Richmond, Va., on brief) for appellant.

David A. Moore, Tax Div., U.S. Dept. of Justice (Glenn L. Archer, Jr., Asst. Atty. Gen., Roger M. Olsen, Acting Asst. Atty. Gen., Michael L. Paup, Chief, Appellate Section, Robert A. Bernstein, Washington, D.C., on brief) for appellee.

Before WINTER, Chief Judge, ERVIN, Circuit Judge, and HAYNSWORTH, Senior Circuit Judge.

PER CURIAM.

The Virginia Education Fund ("Fund") appeals from the judgment of the Tax Court, Virginia Education Fund v. Commissioner, 85 T.C. 44 (1985), upholding the revocation by Internal Revenue Service ("IRS") of the Fund's tax-exempt status, applied retroactively to 1974. The Fund was originally created in the wake of Brown v. Board of Education, 347 U.S. 483, 73 S.Ct. 686, 98 L.Ed. 873 (1954), to solicit monies for...

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