Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined the following income tax deficiencies against The Brook, Inc. (hereinafter "petitioner") for its tax years ending August 31, 1979 and August 31, 1980:
Tax year ended Amount August 31, 1979 ............. $2,072 August 31, 1980 ............. 2,931
The only issue for decision is whether petitioner, a private social club exempt...
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