OPINION
RAUM, Judge:
The Commissioner determined that petitioner does not qualify for exemption from income taxation as an organization described in section 501(c)(3), I.R.C. 1954. Petitioner has invoked the jurisdiction of this Court to obtain a declaratory judgment as to its exempt status under section 501(c)(3).1 The question presented is whether petitioner is operated exclusively for charitable purposes within the...
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