The following procedural limitations apply to a suit for declaratory judgment:
- The petition must be filed by the organization whose qualification for exemption or classification is at issue;
- A petition for declaratory judgment must be filed with the appropriate court (as specified in Declaratory judgments) before the 91st day after the date on which the Internal Revenue Service has mailed a notice of its determination by certified or registered mail; and
- A declaratory judgment will not be issued unless the organization has exhausted the administrative remedies available to it within the IRS.
No action may be brought challenging revocation for failure to file annual returns or reports.