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P.L.L. SCHOLARSHIP FUND v. COMMISSIONER

Docket No. 29579-82X.

82 T.C. 196 (1984)

P.L.L. SCHOLARSHIP FUND, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 26, 1984.

Attorney(s) appearing for the Case

James R. Monroe, for the petitioner.

Genelle F. Forsberg, for the respondent.

OPINION

PATE, Special Trial Judge:

The petitioner has, pursuant to section 7428,1 invoked the jurisdiction of this Court to determine whether it is exempt from Federal income tax under section 501(c)(3). The statutory requirements for this Court's declaratory judgment jurisdiction have been satisfied. The question presented is whether the petitioner is operated exclusively for charitable purposes within the meaning of...

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