MEMORANDUM OPINION
REGGIE B. WALTON, District Judge.
This case arises from a claim brought under a section of the Internal Revenue Code, specifically, 26 U.S.C. § 7428(a)(2) (2006), which allows a party to request declaratory relief from a United States District Court if the Internal Revenue Service ("IRS") fails to make a determination on its request for tax-exempt status within 270 days, Complaint ("Compl.") at 1, and the case is currently...
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