The Church of the Living Tree - Page 2

                                          2                                           
          Tax Court Rules of Practice and Procedure, except as otherwise              
          noted.                                                                      
               At the time of filing the petition herein, petitioner was              
          located in Leggett, California.                                             
               Respondent having filed with her answer herein the index of            
          the administrative record, under Rule 213(a)(3), and the parties            
          having stipulated the full administrative record, the case is to            
          be decided on the basis of such administrative record, Rule 217.            
          By stipulation of the parties, the case was submitted under Rule            
          122.  As specified in Rule 210(c), the Court has jurisdiction of            
          this action for declaratory judgment in that respondent has                 
          issued an adverse determination as to petitioner's qualification            
          for exemption under section 501(c)(3); petitioner organization              
          was in existence at the time this action was brought; this                  
          petition was brought within the time limits of section                      
          7428(b)(3); and respondent has conceded that petitioner has                 
          exhausted available administrative remedies.  The facts found               
          herein are those in the administrative record as stipulated by              
          the parties.  Rule 217(b)(1).                                               
               Petitioner is an unincorporated association organized on               
          July 8, 1992.  Its articles of organization were submitted and              
          signed by John Stahl as founder, and he, together with two other            
          individuals, became the initial trustees and the governing body             
          of petitioner.  The organizational documents provide for "project           
          communities" at various places, each of which will elect a                  




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