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PIUS XII ACADEMY, INC. v. COMMISSIONER

Docket No. 19842-80X.

43 T.C.M. 634 (1982)

T.C. Memo. 1982-97

Pius XII Academy, Inc. v. Commissioner.

United States Tax Court.

Filed February 23, 1982.

Attorney(s) appearing for the Case

John F. Heath, for the petitioner. Howard Berger, for the respondent.

Memorandum Opinion

FORRESTER, Judge:

Respondent determined that petitioner does not qualify for exemption from Federal income tax under section 501(c)(3).1 Petitioner challenges respondent's determination and has invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428.2 The issues for decision are: (1) whether the administrative record contains sufficient information...

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