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MANNING ASSOCIATION v. COMMISSIONER

Docket No. 13332-88X.

93 T.C. 596 (1989)

MANNING ASSOCIATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 15, 1989.

Attorney(s) appearing for the Case

Steven J. Dunn, for the petitioner.

Mae J. Lew, for the respondent.

OPINION

RAUM, Judge:

The Commissioner determined that petitioner does not qualify for exemption from income taxation under section 501(c)(3).1 This case is before us on a petition for a declaratory judgment and a stipulation of the parties as to the correctness and completeness of the administrative record pursuant to Rule 217. The jurisdictional requirements specified in section...

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