DRENNEN, Judge:
This is an action for declaratory judgment pursuant to section 7428(a), I.R.C. 1954.
Respondent issued a final adverse determination to petitioner on April 25, 1978, in which petitioner's previously granted tax-exempt status under section 501(c)(3) was retroactively revoked. The revocation was effective as of April 23, 1971, the date petitioner was organized. Based upon an examination of petitioner's activities...
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