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CHURCH OF ETHEREAL JOY v. COMMISSIONER

Docket No. 9727-83X.

83 T.C. 20 (1984)

CHURCH OF ETHEREAL JOY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 17, 1984.

Attorney(s) appearing for the Case

Glenda Burnside, Michael L. Morgan, and David Snow (officers), for the petitioner.

Deborah A. Butler, for the respondent.

OPINION

FEATHERSTON, Judge:

In this action, petitioner seeks a declaratory judgment pursuant to section 7428(a)1 that it qualifies for tax-exempt status under section 501(c)(3) and as a church under section 509(a)(1). Upon completion of the administrative consideration of petitioner's status, the Internal Revenue Service issued a ruling in part as follows:

This is a final adverse determination with respect to your...

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