T.C. Memo. 1997-220
UNITED STATES TAX COURT
OLIVER FAMILY FOUNDATION, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8346-96X. Filed May 8, 1997.
William J. Tully (an officer), for petitioner.
Kirk M. Paxson and Irene S. Carroll, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: Petitioner, pursuant to section 7428,1 asks
for a declaratory judgment that it is entitled to an exemption
from Federal income taxes under section 501(c)(3). Respondent
filed a motion to dismiss for lack of jurisdiction upon the
1 All section references are to the Internal Revenue Code
in effect for the years in issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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