-7- protest, respondent informed petitioner by letter on November 10, 2004, that its application had been closed because the August 31, 2004, letter exceeded the specified deadline. Discussion Jurisdiction, vested in this Court to provide declaratory relief with respect to the qualification of an organization as an exempt organization described in either section 501(c)(3) or section 170(c)(2), is circumscribed to those instances in which we have determined that the organization has exhausted its administrative remedies. Sec. 7428(b)(2); see Am. New Covenant Church v. Commissioner, 74 T.C. 293, 300 (1980); B.H.W. Anesthesia Found. v. Commissioner, 72 T.C. 681, 682 n.2 (1979). The exhaustion of administrative remedies obligation set forth in section 7428(b)(2) is predicated on the filing of a “substantially completed” application within the meaning of section 601.201(n)(7)(i), Statement of Procedural Rules, and “the timely submission of all additional information requested to perfect” such application. Sec. 601.201(n)(7)(iv)(a) and (b), Statement of Procedural Rules. (This requirement is also borne out in the legislative history of section 7428. See H. Rept. 94- 658, at 267-268 (1975), 1976-3 C.B. (Vol. 2) 695, 979-980; S. Rept. 94-938, at 590 (1976), 1976-3 C.B. (Vol. 3) 49, 628.) As delineated, a substantially completed application entails, among other things, the submission of a proposed budget, currentPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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