Memorandum Opinion
FAY, Judge:
In 1985, after examining the records and activities of New Faith, Inc., for the period ended December 31, 1982, respondent revoked petitioner's tax-exempt status for the tax year ended December 31, 1982, and all subsequent years. Petitioner challenges respondent's determination and has invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428.
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