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HIGH ADVENTURE MINISTRIES, INC. v. C.I.R.

No. 83-7245.

726 F.2d 555 (1984)

HIGH ADVENTURE MINISTRIES, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided February 22, 1984.

Attorney(s) appearing for the Case

Ronald J. Maciel, Hanford, Cal., for petitioner-appellant.

Jay W. Miller, Washington, D.C., for respondent-appellee.

Before SCHROEDER and REINHARDT, Circuit Judges, and SOLOMON, Senior District Judge.

REINHARDT, Circuit Judge:

Petitioner, High Adventure Ministries, Inc., appeals an order of the Tax Court, 80 T.C. 292, dismissing its claims for a declaratory judgment and injunctive relief on the ground that the court lacked jurisdiction under section 7428 of the Internal Revenue Code. The Tax Court held that there was no actual controversy regarding a determination of High Adventure's continuing qualification as an exempt organization...

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