OPINION
STERRETT, Judge:
Respondent, on August 28, 1978, issued a final adverse determination with respect to petitioner's exempt status under section 501(c)(3), I.R.C. 1954. This is an action for declaratory relief under the terms of section 7428.
The administrative record, which includes all the facts upon which respondent made his final adverse determination, was submitted to this Court under Rule 217(b)(1), Tax Court Rules of Practice...
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