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WENDY L. PARKER REHABILITATION FOUNDATION, INC. v. COMMISSIONER

Docket No. 855-85X.

52 T.C.M. 51 (1986)

T.C. Memo. 1986-348

Wendy L. Parker Rehabilitation Foundation, Inc. v. Commissioner.

United States Tax Court.

Filed August 4, 1986.

Attorney(s) appearing for the Case

Sidney Meyers, for the petitioner. Kevin C. Reilly, for the respondent.

Memorandum Opinion

GERBER, Judge:

Petitioner seeks a declaratory judgment, pursuant to section 7428,1 that it is an organization exempt from taxation under section 501(c)(3). The issue presented for our consideration is whether petitioner meets the section 501(c)(3) requirement that no part of its net earnings inure to the benefit of a private individual.

This case was submitted for decision pursuant to Rules 122 and...

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