Florida Independent Colleges and Universities Risk Management Association, Inc. v. Internal Revenue Service

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 will enter summary judgment in favor of the defendants.

I. BACKGROUND

The plaintiff, Florida Independent Colleges and Universities Risk Management…