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CHURCH OF MODERN ENLIGHTENMENT v. COMMISSIONER

Docket No. 18581-84X.

55 T.C.M. 1304 (1988)

T.C. Memo. 1988-312

Church of Modern Enlightenment v. Commissioner.

United States Tax Court.

Filed July 25, 1988.

Attorney(s) appearing for the Case

Richard A. Engert (an officer), 484 67th St., Brooklyn, N.Y., for the petitioner. Gail A. Berruti, for the respondent.

Memorandum Opinion

WHALEN, Judge:

This is an action for declaratory judgment pursuant to section 7428,1 that petitioner qualifies as a religious organization exempt from taxation under section 501(c)(3). Respondent refused to recognize petitioner as such an organization based upon his determination that petitioner is not operated exclusively for exempt purposes as required by section 501(c)(3).

The issue for decision...

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