OPINION OF THE COURT
ADAMS, Circuit Judge.
This is an appeal from a decision of the United States Tax Court affirming the Internal Revenue Service's (IRS) revocation of tax-exempt status for a religiously-oriented publishing house. The Tax Court's decision affirming the termination of the publisher's 52-year-old tax-exemption under 26 U.S.C. § 501(c)(3) (1982),
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