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PULPIT RESOURCE v. COMMISSIONER

Docket No. 7976-77X.

70 T.C. 594 (1978)

PULPIT RESOURCE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 31, 1978.

Attorney(s) appearing for the Case

Glendon E. Harris (an officer), for the petitioner.

William J. Salica and Ray K. Kamikawa, for the respondent.

OPINION

DRENNEN, Judge:

This is an action for declaratory judgment pursuant to section 7428(a), I.R.C. 1954.1

Respondent issued a final adverse ruling on April 13, 1977, with respect to petitioner's application for exempt status under section 501(a) on the ground that petitioner's operation is similar to a commercial enterprise operated for profit and, therefore, is not operated exclusively for any of the purposes...

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