OPINION
STERRETT, Chief Judge:
This is an action for declaratory judgment under section 7428, I.R.C. 1954. At issue is petitioner's status as a tax-exempt religious organization under section 501(c)(3). Resolution of that issue turns on: (1) Whether petitioner is operated exclusively for exempt purposes; and (2) whether any part of petitioner's net earnings inures to the benefit of any private individual.
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