MEMORANDUM OPINION
COHEN, Chief Judge:
Respondent determined that Wayne Baseball, Inc. (petitioner), does not qualify as a section 501(c)(3) charitable organization and, therefore, is not exempt from Federal taxation under section 501(a). Pursuant to section 7428 and title XXI of the Tax Court Rules of Practice and Procedure, petitioner seeks a declaratory judgment that it is a qualified organization under section 501(c)(3). The administrative record, which...
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