Music Square Church v. United States
Court of Appeals for the Federal Circuit
1Opinion of the Court
CLEVENGER, Circuit Judge.
Music Square Church (MSC) appeals the dismissal of its complaint with prejudice. See Music Square Church v. United States, No. 96-396T (Fed.Cl. Apr. 15, 1999). We affirm.
I
MSC is a church founded by Tony and Susan Alamo. The Internal Revenue Service (IRS) recognized MSC as a tax-exempt organization under 26 U.S.C. § 501(c) in 1981. In a Final Adverse Determination letter dated April 5, 1996, however, the Commissioner of Internal Revenue determined that MSC was not an organization described in 26 U.S.C. § 501(c), and revoked MSC’s tax-exempt status effective April 3,…
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