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UNIVERSITY HILL FOUNDATION v. COMMISSIONER

Docket Nos. 73993, 5311-65, 1482-66.

51 T.C. 548 (1969)

UNIVERSITY HILL FOUNDATION, FORMERLY LOYOLA UNIVERSITY FOUNDATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 8, 1969.

Attorney(s) appearing for the Case

Austin H. Peck, Jr., Dana Latham, and Henry J. Steinman, Jr., for the petition.

Richard W. Janes and J. Earl Gardner, for the respondent.

TANNENWALD, Judge:

These consolidated proceedings involve income and excess profits taxes for the fiscal years ended April 30, 1952, through April 30, 1965, in the aggregate amount of $10,070,677.25. The principal questions in issue are whether petitioner is exempt from Federal income tax under sections 501(c)(3) of the 1954 Code and 101(6) of the 1939 Code; whether petitioner is a "feeder organization" within the meaning...

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