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Detroit Area Council, specifically the troops in
Northville, Michigan. [Exhibit references omitted.]
Petitioner also alleges to have provided $10,000 to the First
Presbyterian Church of Northville in 2000. Petitioner elsewhere
states that neither the proposal concerning the Boy Scouts nor
the offer to convert the promissory note to demand note was acted
upon.
Respondent objects to factual assertions purportedly derived
from the amended articles and bylaws. In this connection,
respondent emphasizes that the record does not establish that the
proposed changes were formally implemented, nor does it show the
financial wherewithal of petitioner to support additional
beneficiaries at the level alleged.
Rule 217 governs procedural matters relevant to disposition
of actions for declaratory judgment. Paragraph (a) of Rule 217
provides:
Disposition of an action for declaratory judgment,
which does not involve either a revocation or the
status of a governmental obligation, will ordinarily be
made on the basis of the administrative record, as
defined in Rule 210(b)(10). Only with the permission
of the Court, upon good cause shown, will any party be
permitted to introduce before the Court any evidence
other than that presented before the Internal Revenue
Service and contained in the administrative record as
so defined. * * *
The referenced Rule 210(b)(10), as germane herein, defines the
administrative record to include the request for determination;
all documents, protests, and related papers submitted to the IRS;
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