- 2 - grounds that: (1) Petitioner was not organized exclusively for exempt purposes; (2) petitioner was not operated exclusively for exempt purposes; and (3) petitioner failed to establish that it did not operate for a substantial nonexempt purpose. Pursuant to section 7428, petitioner seeks a declaratory judgment that respondent’s denial of its request for tax-exempt status was erroneous and that petitioner qualifies for tax-exempt status under section 501(c)(3). The matter is now before us on respondent’s Motion For Summary Judgment. Background Petitioner’s only involvement in this case has been to file the petition and a designation of place of submission. See Rules 211(a) and 212. Thereafter, petitioner did not, or would not, participate in stipulating to the administrative record, as defined in Rule 210(b)(12). See Rule 217(a). As a consequence, respondent filed the entire administrative record, appropriately certified as to its genuineness by an official authorized to act for the Commissioner. See Rule 217(b)(1). The following is drawn from that record. 1(...continued) references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008