GUSTAFSON, Judge:
After examining the activities of petitioner, Partners In Charity, Inc. ("PIC"), for the years 2002 and 2003, the Internal Revenue Service ("IRS") issued to PIC a final adverse determination letter dated October 22, 2010, revoking its recognition of PIC's tax-exempt status. The revocation was retroactively effective to the date of PIC's incorporation on July 10, 2000. On January 20, 2011, PIC timely petitioned this Court pursuant to section...
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