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balance sheet, statement of proposed activities, and description
of anticipated receipts and contemplated expenditures. Sec.
601.201(n)(7)(i), Statement of Procedural Rules; see also Rev.
Proc. 90-27, 1990-1 C.B. 514. Additionally, other procedural
regulations mandate that an organization “fully describe the
activities in which it expects to engage, including the
standards, criteria, procedures, or other means adopted or
planned for carrying out the activities; the anticipated sources
of receipts; and the nature of contemplated expenditures.” Sec.
601.201(n)(1)(ii), Statement of Procedural Rules.
The facts stipulated support a conclusion that petitioner
has not exhausted its administrative remedies, and therefore,
jurisdiction is not available. As elaborated on below,
petitioner’s belated responses to respondent’s inquiries in the
course of processing its application evince petitioner’s failure
to “[complete] the normal progression through administrative
channels,” B.H.W. Anesthesia Found. v. Commissioner, supra, at
682 n.2, or to “demonstrate that progress * * * [was] severely
hampered due to causes beyond its control,” Prince Corp. v.
Commissioner, 67 T.C. 318, 328 (1976) (finding failure to exhaust
administrative remedies in the context of section 7476(b)(3), the
counterpart to section 7428(b)(2) in the area of retirement
plans).
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