Memorandum Opinion
NIMS, Judge.
Petitioner seeks a declaratory judgment under section 7428(a) that it is exempt from Federal income tax under section 501(a) as an organization meeting the requirements of section 501(c)(3). (All section references are to sections of the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure.) The case has been submitted on the basis of the administrative record. Petitioner has...
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