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minor differences, the organizations and requirements listed in
section 170(c)(2) are virtually identical to those described in
section 501(c)(3). With limited exceptions not here relevant,
organizations described in the other paragraphs of section 501(c)
are not eligible to receive tax-deductible contributions.
In the event the Commissioner determines that an
organization does not qualify for tax-exempt status, the
organization may (after exhausting its administrative remedies)
seek judicial review of the matter. Section 7428(a) confers
jurisdiction on the Tax Court, among other courts, to make a
declaration with respect to the initial or continuing
qualification of an organization as an organization described in
section 501(c)(3). See Houston Lawyer Referral Serv., Inc. v.
Commissioner, 69 T.C. 570, 571 (1978).
It is well established that the scope of our inquiry is
limited to the propriety of the reasons given by the Commissioner
for denying an organization's application for exemption. See Aid
to Artisans, Inc. v. Commissioner, 71 T.C. 202, 208 (1978).
Thus, in making our declaration, we do not engage in a de novo
review of the administrative record. See Am. Campaign Acad. v.
Commissioner, supra at 1063; Church in Boston v. Commissioner, 71
T.C. 102, 105-106 (1978); Houston Lawyer Referral Serv., Inc. v.
Commissioner, supra at 573-574, 577. The burden of proof is on
the organization to overcome the grounds for denial of the
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