MEMORANDUM OPINION
Granting Defendant's Motion for Summary Judgment
URBINA, District Judge.
Plaintiff, The Fund for the Study of Economic Growth and Tax Reform (Fund), pursuant to 26 U.S.C. § 7428, seeks a declaratory judgment that it is a tax exempt organization under § 501(c)(3) of the United States Internal Revenue Code. Defendant, Internal Revenue Service (IRS), denied the Fund tax exempt status because it did not operate exclusively...
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