Memorandum Opinion
MURDOCK, Judge:
The Commissioner determined a deficiency of $27,293.15 in income tax of the petitioner for 1958. The only issue for decision is whether the petitioner is exempt from tax under section 501(c)(3), Internal Revenue Code of 1954. The return was filed with the district director of internal revenue for the Lower Manhattan District of New York.
The parties have filed a stipulation of facts which is adopted as the findings...
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