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INTERNATIONAL E22 CLASS ASSN. v. COMMISSIONER

Docket No. 16074-80X.

78 T.C. 93 (1982)

INTERNATIONAL E22 CLASS ASSOCIATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 25, 1982.

Attorney(s) appearing for the Case

Michael J. Rufkahr, Mary F. Voce, and Paul J. Henry, for the petitioner.

Kevin W. Cobb, for the respondent.

OPINION

WILBUR, Judge:

Petitioner requested a determination by respondent of petitioner's qualification as an exempt organization described in section 501(c)(3).1 No notice of determination has been issued in this matter by respondent. Petitioner therefore invokes the jurisdiction of this Court for a declaratory judgment pursuant to section 7428.2 The sole issue for our

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