Memorandum Opinion
SMITH, J.:
This proceeding involves deficiencies in income tax and excess profits tax for 1938 in the respective amounts of $5,205.41 and $4,125.18. The question in issue is whether petitioner is exempt from tax as a corporation organized and operated exclusively for charitable purposes, or, in the alternative, whether its receipts during the taxable year from fees paid by its guests were in whole or in part trust funds and therefore not...
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