Memorandum Opinion
NIMS, Judge:
The Commissioner 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). (Unless otherwise indicated, all section references are to the Internal Revenue Code in effect when the petition was filed. All Rule references are to the Tax Court Rules of Practice and Procedure.) Petitioner challenges respondent's determination by invoking...
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