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PIETY, INC. v. COMMISSIONER

Docket No. 28128-82X.

82 T.C. 193 (1984)

PIETY, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 26, 1984.

Attorney(s) appearing for the Case

Rex K. Holmes (an officer), for the petitioner.

Judith M. Picken, for the respondent.

OPINION

CLAPP, Judge:

Respondent determined petitioner is not exempt from taxation under section 501(c)(3). Pursuant to section 7428,1 petitioner, having exhausted its administrative remedies, challenges that determination and seeks a declaration by this Court with respect to its initial qualification under section 501(c)(3).

This case was submitted under Tax Court Rule...

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