Create (Christian, Research, Education, Action, Technical Enterprise), Inc. v. Commissioner of Internal Revenue

RANDALL, Circuit Judge:

We are asked in this case to determine whether the United States Tax Court has jurisdiction under I.R.C. § 7428 1 to enter tain an action, by an organization that was successful in obtaining rulings from the Internal Revenue Service to the effect that it was a public charity under I.R.C. §§ 509(aXl) and 509(a)(3), for a declaratory judgment with respect to an issue presented in one of the organization’s ruling requests which was determined adversely to the organization and which could adversely affect the organization’s public charity status in the future. The Tax Court…