The Reagan administration has given tax-exempt status back to Prince Edward Academy, the private school that became a symbol of Virginia's massive resistance to school integration in the 1950s, even though the academy has no black students.

The Internal Revenue Service reinstated the academy's favored tax status, which it lost in 1978, after school officials stated that it is open to all races and has American Indian, Vietnamese, Spanish, German and French students.

Although the school has 643 Caucasians, it has no blacks because none has ever applied, school officials say.

"I am surprised to see that the academy, by merely making a statement that it doesn't discriminate, would be granted its tax-exempt status back," said James E. Ghee, a lawyer in Farmville, Va., where the school is located, and president of the state NAACP.

"Nothing has changed in the policies or procedures of Prince Edward Academy," Ghee said.

In its application to the IRS, Prince Edward Academy said that last year its board adopted a policy of "open admissions."

The school, which has classes from kindergarten through 12th grade and tuition costs ranging from $800 to $1,550, also published an advertisement of its open admissions policy in The Farmville Herald and promised to stamp its literature with a notice of its nondiscriminatory policy.

Chan Kendrick, Virginia director of the American Civil Liberties Union, called the ruling "laughable. Our position is that the government cannot support racial discrimination, and that's exactly what granting tax-exempt status to this academy does."

Prince Edward Academy was created in 1959, when the community decided to close its public schools rather than allow black students to attend school with whites.

For five years, there were no public schools for blacks in Prince Edward County. Segregationists throughout the South praised the move.

Five years earlier, the Supreme Court's Brown v. Board of Education decision had focused national attention on the Prince Edward County public school system by using it as an example of the failure of a "separate but equal" school system for blacks and whites.

Robert T. Redd, current administrator of the academy, explained to historian Raymond Wolters in 1981 that integration cannot succeed because blacks are, on the average, less intelligent than whites and "simply do not have the ability to do quality work."

The IRS decision, dated Aug. 21, does not explain the reversal of the academy's status, except to say that the decision was "based on information supplied . . . . "

The tax-exempt status, which is retroactive to Oct. 3, 1984, will not only free the academy from federal tax liability but also allow contributors to deduct their gifts to the school on their federal income tax returns. In the past, denial of the tax-exempt status was seen as a powerful tool by those attempting to stop the spread of segregationist private schools.

Because private schools often operate at a loss, they often find that tax-exempt status is especially important as a fund-raising tool.

In 1982, the Reagan administration tried to revoke the IRS policy of denying tax-exempt status to all-white schools, a move that would have benefitted the academy and 110 other schools across the country.

But the following year the Supreme Court repudiated the attempt, saying the government can and should withhold tax benefits from such schools.

After unsuccessful court challenges to the IRS ruling, the academy's board decided to adopt the "open admissions" resolution.

According to excerpts of discussions at that meeting, provided to the IRS, the board emphasized "that nothing in its Constitution or bylaws is discriminatory nor has the school practiced racial discrimination in admission practices in its 25-year history."