MEMORANDUM OPINION
ROYCE C. LAMBERTH, Chief Judge.
Before the Court are the parties' cross-motions for summary judgment [16][17]. The plaintiff, an association of tax-exempt secondary schools and universities in Florida organized to pool risk and obtain insurance, seeks a declaratory judgment that it too is tax-exempt. Upon consideration of the motions, the objections and replies thereto, the applicable law, and the entire record herein, the Court...
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