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FRIENDS OF SOC. OF SERVANTS OF GOD v. COMMISSIONER

Docket No. 14485-79X.

75 T.C. 209 (1980)

FRIENDS OF THE SOCIETY OF SERVANTS OF GOD, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 12, 1980.

Attorney(s) appearing for the Case

Paul J. Sax and Dean E. Criddle, for the petitioner.

Bernard B. Kornmehl and Joyce E. Britt, for the respondent.

OPINION

FAY, Judge:

Petitioner seeks a declaratory judgment and challenges respondent's determination that petitioner was not a "church" within the meaning of section 170(b)(1)(A)(i)1 for purposes of determining whether it was a private foundation under section 509(a)(1). Respondent has moved to dismiss for lack of jurisdiction on the ground that petitioner received a favorable ruling that it was not a private foundation...

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