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EO - Declaratory Judgments Under IRC 7428

Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States

IRC 7428 provides for the judicial review of certain final adverse EO determinations by either the United States Tax Court, the United States Court of Federal Claims or the United States District Court for the District of Columbia (IRC 7428).

Matters subject to court review covered under IRC 7428(a)(1) include disagreements on an organization’s initial or continuing qualification under IRC 501(c)(3).

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