Memorandum Findings of Fact and Opinion
ARNOLD, Judge:
This proceeding involves deficiencies in income taxes for the fiscal years ended February 28, 1938 and 1939, in the respective amounts of $1,010.26 and $591.87. The first issue is whether petitioner is an exempt corporation within the meaning of section 101(9), Revenue Acts of 1936 and 1938. If exemption is denied, the further question is presented of whether initiation fees received in each year and...
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