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PRIZE v. COMMISSIONER

Docket No. 18658-02X.

87 T.C.M. 813 (2004)

T.C. Memo. 2004-12

Peoples Prize v. Commissioner.

United States Tax Court.

Filed January 15, 2004.

Attorney(s) appearing for the Case

Daniel L. Pfaff (President), for the petitioner.

Elizabeth Edwards and Michael Blumenfeld, for the respondent.

MEMORANDUM OPINION

HAINES, Judge.

Respondent determined that Peoples Prize does not qualify as an organization described in section 501(c)(3) and consequently is not exempt from Federal income tax under section 501(a). Petitioner challenged respondent's determination by timely filing a petition for a declaratory judgment pursuant to section 7428(a) after exhausting its administrative remedies and satisfying jurisdictional requirements. See sec. 7428(b)(3...

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