United States Tax Court July 31, 1978, Docket No. 7976-77X (Pulpit Resource v. Commissioner)

OPINION

Drennen, Judge:

This is an action for declaratory judgment pursuant to section 7428(a), I.R.C. 1954.1

Respondent issued a final adverse ruling on April 13, 1977, with respect to petitioner’s application for exempt status under section 501(a) on the ground that petitioner’s operation is similar to a commercial enterprise operated for profit and, therefore, is not operated exclusively for