OPINION.
MURDOCK, Judge:
The Commissioner determined deficiencies in income tax of $704.31 for 1950 and $1,193.11 for 1951. The only issue for decision is whether the petitioner is exempt from taxation under section 101 (9) of the Internal Revenue Code as a social club. The parties have filed a stipulation which is adopted as the findings of fact.
The petitioner was incorporated in 1933 under the laws of Pennsylvania. Its constitution and...
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