National Paralegal Inst. Coalition - Page 2


               Arthur Carson (an officer), for petitioner.                              
               Helen F. Rogers, for respondent.                                         

                                  MEMORANDUM OPINION                                    
               NIMS, Judge:  Petitioner brought an action for a declaratory             
          judgment pursuant to section 7428 and Rule 211 on the ground that             
          respondent had failed to determine whether petitioner qualifies               
          as an organization exempt from taxation under section 501(a),                 
          (c)(3) and (4).  Unless otherwise indicated, all Rule references              
          are to the Tax Court Rules of Practice and Procedure, and all                 
          section references are to the Internal Revenue Code.  This case               
          is before us on respondent’s motion to dismiss for lack of                    
          jurisdiction on the ground that petitioner did not exhaust its                
          administrative remedies pursuant to section 7428(b)(2).                       
               This case is submitted for decision on a comprehensive                   
          stipulation of facts, which is incorporated herein by this                    
               Petitioner, National Paralegal Inst. Coalition, was                      
          organized as a nonprofit corporation in Texas on March 29, 2001.              
          On January 11, 2002, it submitted a Form 1023, Application for                
          Recognition of Exemption Under Section 501(c)(3)(petitioner’s                 

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