Citation Codes Equivalent Citations citation codes Docket Number Civil Action No. 02-0785 (EGS) Judges Emmet G. Sullivan Acts Internal Revenue Code — Income Taxes — Normal Taxes And Surtaxes — Exempt Organizations — General Rule — Exemption From Tax On Corporations, Certain Trusts, Etc. See more information ... Smart Summary Please sign up to generate summary. OPINION AIRLIE FOUNDATION, Plaintiff, v. INTERNAL REVENUE SERVICE, Defendant ORDER AND JUDGMENT EMMET SULLIVAN, District Judge Pursuant to Fed.R.Civ.P. 58 and for the reasons stated by the Court in its Memorandum Opinion docketed this same day, it is by the Court hereby ORDERED that plaintiff's motion for summary judgment is denied; and it is FURTHER ORDERED that defendant's cross-motion for summary judgment is granted; and it is FURTHER ORDERED and ADJUDGED that the Clerk shall enter final judgment in favor of defendant and against plaintiff, which judgment shall declare that plaintiff is not entitled to tax-exempt status pursuant to 26 U.S.C. § 501 (c)(3).