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FREE FERTILITY FOUND. v. COMMISSIONER

Docket No. 17122-07X.

135 T.C. 21 (2010)

FREE FERTILITY FOUNDATION, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed July 7, 2010.

Attorney(s) appearing for the Case

Marcus S. Owens and Nancy Ortmeyer Kuhn, for petitioner.

Philip T. Hackney and Michael B. Blumenfeld, for respondent.

OPINION

FOLEY, Judge:

Pursuant to section 7428(a),1 petitioner seeks a declaratory judgment that it meets the requirements of section 501(c)(3) and is exempt from Federal income taxation. This case was submitted for decision based on the stipulated administrative record as defined in Rule 210(b)(12). Petitioner has exhausted its administrative remedies as required by section 7428...

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