What is the test for declaratory judgment under Section 2201 of the Declaratory Judgment Act?

The Declaratory Judgment Act, 28 U.S.C. Sec. 2201, gives district courts jurisdiction to declare parties' rights, but ordinarily prohibits declaratory judgment in actions involving federal taxes. California v. Regan, 641 F.2d 721, 722-23 (9th Cir.1981). The only relevant exception to this prohibition is the exception for actions brought under 26 U.S.C. Sec. 7428, which provides for declaratory judgments concerning the status of organizations under 26 U.S.C. Sec. 501(c)(3). ¹ High Adventure Ministries, Inc. v. Commissioner, 726 F.2d 555, 556 (9th Cir.1984). The question then is, whether this action was properly brought under 26 U.S.C. Sec. 7428.