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MICHIGAN EARLY CHILDHOOD CENTER, INC. v. COMMISSIONER

Docket No. 9824-77X.

37 T.C.M. 808 (1978)

T.C. Memo. 1978-186

Michigan Early Childhood Center, Inc. v. Commissioner.

United States Tax Court.

Filed May 22, 1978.

Attorney(s) appearing for the Case

Kathryn J. Cole (an officer), 537 N. Clippert St., Lansing, Mich., for the petitioner. Kevin M. Bagley, for the respondent.

Memorandum Opinion

SCOTT, Judge:

Petitioner has brought this action for a declaratory judgment pursuant to section 7428, I.R.C. 1954,1 challenging respondent's determination in his final letter of adverse determination issued June 24, 1977. In this letter respondent determined that petitioner did not qualify for exemption from Federal income tax under section 501(c)(3) because:

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