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URANTIA FOUNDATION v. C. I. R.

No. 81-2911.

684 F.2d 521 (1982)

URANTIA FOUNDATION, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Seventh Circuit.

Decided August 4, 1982.

Attorney(s) appearing for the Case

Quin R. Frazer, Chicago, Ill., for appellant.

Richard Farber and Jo-Ann Horn, U. S. Dept. of Justice, Tax Div., Washington, D. C., for appellee.

Before POSNER and COFFEY, Circuit Judges, and CAMPBELL, Senior District Judge.

WILLIAM J. CAMPBELL, Senior District Judge.

Appellant, Urantia Foundation (hereafter "Foundation"), filed a petition with the Tax Court seeking a declaratory judgment to invalidate a letter ruling of the Internal Revenue Service. The Foundation alleged jurisdiction for the petition under 26 U.S.C. § 7428(a)(1).1 However, the Tax Court dismissed the petition concluding that it presented no actual controversy and that the letter ruling...

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