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LECKIE SCHOLARSHIP FUND v. COMMISSIONER

Docket No. 5028-84X.

87 T.C. 251 (1986)

THE "MISS ELIZABETH" D. LECKIE SCHOLARSHIP FUND, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 30, 1986.

Attorney(s) appearing for the Case

David M. Wooldridge and Allan J. Chappelle, for the petitioner.

Dianne I. Crosby, for the respondent.

OPINION

GERBER, Judge:

Petitioner brings this action for a declaratory judgment, pursuant to section 7428,1 seeking a redetermination of respondent's adverse ruling as to petitioner's status as an operating foundation under section 4942(j)(3). The record in this case consists of a stipulated administrative record with attached exhibits, and is incorporated herein by this reference. See Rules 210(b)(11) and 217(a).

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