American Guidance Foundation, Inc. v. United States

MEMORANDUM AND ORDER

GESELL, District Judge.

Plaintiff, American Guidance Foundation, Inc. (“AGF”), a non-stock non-profit corporation operating in Philadelphia, seeks to be declared a “church” for tax purposes. After four years of administrative controversy, the Internal Revenue Service (“IRS”) rejected AGF’s request, leaving it classified as a private foundation, see 26 U.S.C. § 509(a) (1976), but not as a church, see 26 U.S.C. § 170(b)(1)(A)(i) (1976). Having exhausted its administrative remedies, plaintiff is properly before the Court. 26 U.S.C. § 7428(a)(1)(B) (1976). Thorough briefs were…