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LABRENZ FOUNDATION, INC. v. COMMISSIONER

Docket No. 5175-73.

33 T.C.M. 1374 (1974)

T.C. Memo. 1974-296

The Labrenz Foundation, Inc. v. Commissioner.

United States Tax Court.

Filed November 26, 1974.

Attorney(s) appearing for the Case

John F. Papsidero, 518 Statler Hilton Hotel, Buffalo, N.Y., for the petitioner. Stephen M. Miller, for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

Respondent determined a deficiency in petitioner's income tax for 1970 in the amount of $3,063.05, plus an addition to tax under section 6651(a)1 in the amount of $612.61. The issue for decision is whether petitioner was exempt from Federal income taxes during 1970 under section 501(c)(3). The answer depends upon whether petitioner was operated exclusively for charitable...

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