37 T.C.M. 808 (1978)
T.C. Memo. 1978-186
Michigan Early Childhood Center, Inc. v. Commissioner.
United States Tax Court.https://leagle.com/images/logo.png
Filed May 22, 1978.
Filed May 22, 1978.
Kathryn J. Cole (an officer), 537 N. Clippert St., Lansing, Mich., for the petitioner. Kevin M. Bagley, for the respondent.
SCOTT, Judge:
Petitioner has brought this action for a declaratory judgment pursuant to section 7428, I.R.C. 1954,1 challenging respondent's determination in his final letter of adverse determination issued June 24, 1977. In this letter respondent determined that petitioner did not qualify for exemption from Federal income tax under section 501(c)(3) because:
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