Memorandum Opinion
COHEN, Judge:
Respondent determined that petitioner does not qualify for exemption from Federal income tax under section 501(a) as an organization described in section 501(c)(3). Petitioner challenges respondent's determination and has invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428. The issue for decision is whether petitioner is operated exclusively for an exempt purpose within the meaning of...
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