The District Court for the District of Columbia released its opinion in DLC, Inc. v. USA. Among the issues involved was the propriety of the IRS’s retroactive revocation of the DLC’s 501(c)(4) status. The court concludes (footnote omitted):
It may be that the DLC is unworthy of 501(c)(4) status. But the Government gave it that status and cannot retroactively revoke it in these circumstances. An accompanying order will grant the DLC’s motion for summary judgment and deny the Government’s motion for summary judgment. The foregoing does not preclude the IRS from revoking prospectively the DLC’s exempt status, should it conclude again that the DLC is not entitled to that status.