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CHURCH OF ETERNAL LIFE AND LIBERTY, INC. v. COMMISSIONER

Docket No. 27487-82X.

86 T.C. 916 (1986)

THE CHURCH OF ETERNAL LIFE AND LIBERTY, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 29, 1986.

Attorney(s) appearing for the Case

Patrick A. Heller (a director), for the petitioner.

Roberta M. Hamm, for the respondent.

WILLIAMS, Judge:*

The Commissioner determined that petitioner does not qualify for exemption from Federal income taxation under section 501(a)1 as an organization described in section 501(c)(3) or as a church within the meaning of sections 509(a)(1) and 170(b)(1)(A)(i). Petitioner seeks a declaratory judgment of this Court pursuant to section 7428 that it is an exempt organization described in section...

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