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CRSO v. COMMISSIONER

Docket No. 11804-05X.

128 T.C. 153 (2007)

128 T.C. No. 12

CRSO, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 30, 2007.

Attorney(s) appearing for the Case

James J. Workland and Gary C. Randall, for petitioner.

Mark A. Weiner, for respondent.

OPINION

THORNTON, Judge:

Respondent denied petitioner's request for tax-exempt status under section 501(c)(3).1 Pursuant to section 7428, petitioner seeks declaratory relief.

The parties submitted this case to the Court without trial to be decided on the basis of the pleadings and the parties' stipulation as to the administrative record. See Rules 122, 217(b). The Court's decision will be based upon the assumption...

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