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INTERNATIONAL POSTGRADUATE MEDICAL FOUNDATION v. COMMISSIONER

Docket No. 8103-83X.

56 T.C.M. 1140 (1989)

T.C. Memo. 1989-36

International Postgraduate Medical Foundation v. Commissioner.

United States Tax Court.

Filed January 24, 1989.

Attorney(s) appearing for the Case

Ronald K. Van Wert, 1301 Dove St., Newport Beach, Calif., for the petitioner. Joyce M. Resnick, for the respondent.

Memorandum Findings of Fact and Opinion

COLVIN, Judge:

This case presents for decision the issue of whether a not-for-profit corporation that conducted continuing medical educational tours abroad operated exclusively for an exempt purpose under section 501(c)(3).1 The issues for decision are:

1. Whether petitioner operated exclusively for an exempt purpose within the meaning of section 501(c)(3); and

2. Whether...

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