National Paralegal Inst. Coalition - Page 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.                                 
               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, current                    

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