New Dynamics Foundation v. United States
United States Court of Federal Claims
1Opinion of the Court
OPINION
ALLEGRA, Judge.
“[Cjharity begins at home, and justice begins next door.”1
New Dynamics Foundation (plaintiff or NDF) brings this declaratory judgment action under 26 U.S.C. § 7428(a), seeking a declaration that it is exempt from taxation under sections 501(a) and 501(c)(3) of the Internal Revenue Code of 1986 (the Code). After careful consideration of the parties’ briefs and other submissions, review of the certified administrative record, and oral argument, the court finds plaintiff is not entitled to the relief it requests for the reasons set forth below.
I. FACTS
Based upon the…
2Cases cited66 opinions
- Richardson v. PeralesSupreme Court of the United States · 1971
- Maryland Casualty Co. v. Pacific Coal & Oil Co.Supreme Court of the United States · 1941
- Village of Schaumburg v. Citizens for a Better EnvironmentSupreme Court of the United States · 1980
- Beech Aircraft Corp. v. RaineySupreme Court of the United States · 1988
- Interstate Circuit, Inc. v. United StatesSupreme Court of the United States · 1939
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