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RENSSELAER POLYTECHNIC INST. v. COMMISSIONER

Docket No. 7024-79.

79 T.C. 967 (1982)

RENSSELAER POLYTECHNIC INSTITUTE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 1, 1982.

Attorney(s) appearing for the Case

George C. Shattuck, for the petitioner.

Bradford A. Johnson, for the respondent.

OPINION

FAY, Judge:

Respondent determined a deficiency of $12,653.13 in petitioner's Federal income tax for its fiscal year ending June 30, 1974. After concessions, the only issue is the proper method of allocating certain indirect expenses between petitioner's exempt and unrelated activities.

All the facts have been stipulated and are found accordingly.

Petitioner Rensselaer Polytechnic Institute, a nonprofit educational organization...

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