Michael Reese Hospital & Medical Center v. United States

MEMORANDUM OPINION AND ORDER

CONLON, District Judge.

The parties have submitted cross-motions for summary judgment that are dispositive of plaintiffs entire claim for tax refunds. For the following reasons, the court grants defendant’s motion.

Facts

The facts are not in dispute. Plaintiff is a tax-exempt organization under Sections 501(a) and 501(c)(3) of the Internal Revenue Code of 1954, as amended (“Code”), 26 U.S.C. § 1 et seq. Pursuant to Code Section 403(b), plaintiff established a tax-deferred retirement annuity plan for its employees. Participating employees accepted reductions in their…