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MISS GEORGIA SCHOLARSHIP FUND, INC. v. COMMISSIONER

Docket No. 5127-78X.

72 T.C. 267 (1979)

MISS GEORGIA SCHOLARSHIP FUND, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 1, 1979.

Attorney(s) appearing for the Case

S. Davis Laney, for the petitioner.

Bernard B. Kornmehl, for the respondent.

OPINION

QUEALY, Judge:

Respondent determined that petitioner does not qualify for exemption from Federal income tax under section 501(c)(3).1 Petitioner challenges respondent's determination and has invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428. The issue presented to us is whether petitioner is operated exclusively for charitable, religious, or educational purposes within the...

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