MEMORANDUM OPINION
FOLEY, Judge:
Petitioner seeks a declaratory judgment under section 7428(a) that it is exempt from Federal income taxation under section 501(a) as an organization meeting the requirements of section 501(c)(3). Pursuant to Rule 122, this case was submitted for decision based on the stipulated administrative record as defined in Rule 210(b)(10). Petitioner has exhausted its administrative remedies within the Internal Revenue Service as required...
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