OPINION
NIMS, Judge:
Respondent determined that petitioner Quality Auditing Co., Inc., does not qualify for exemption from Federal income taxation under section 501(a) as an organization meeting the requirements of section 501(c)(3). Having exhausted its administrative remedies, petitioner challenged respondent's determination by timely invoking the jurisdiction of this Court for a declaratory judgment pursuant to section 7428(a). The case was submitted...
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