Plaintiffs/respondents, parents of African-American children in seven states where public schools had recently been desegregated, brought a nationwide class action lawsuit against the Internal Revenue Service in federal district court, contending that IRS guidelines and procedures for determining whether private schools were racially discriminatory, and subsequent denial of tax exempt status to such schools, were insufficient. Federal law prohibited tax-exempt status to private schools that discriminate on the basis of race, but the parents contended that the standards the IRS used to determine if a school was discriminating were not capable of identifying all of the discriminating private schools. White parents were therefore able to avoid integration by sending their children to the private schools and deducting charitable contributions to the institution, thereby making it harder for black children to attend integrated schools. The plaintiffs sued the IRS and W. Wayne Allen was granted permission to intervene as the defendant in his official capacity as the chairman of the board of Briarcrest Christian School, a segregation academy founded in 1973 in response to the desegregation of Memphis city schools.