Memorandum Opinion
JACOBS, Judge.
After exhausting its administrative remedies, petitioner seeks a declaratory judgment pursuant to section 7428 that it is a tax exempt organization described in section 501(c)(3). The prerequisites for commencing this action set forth in section 7428, as well as the jurisdictional requirements set forth in Rule 210, have been satisfied.
All section references are to the Internal Revenue Code as in effect at the time...
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