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NORTH AMERICAN SEQUENTIAL SWEEPSTAKES v. COMMISSIONER

Docket No. 4425-78X.

77 T.C. 1087 (1981)

NORTH AMERICAN SEQUENTIAL SWEEPSTAKES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 3, 1981.

Attorney(s) appearing for the Case

Malcolm D. Katz, for the petitioner.

Elizabeth D. DePriest and Richard Shipley, for the respondent.

OPINION

WILES, Judge:

Respondent determined that petitioner does not qualify for exemption from Federal income tax as an organization described in section 501(c)(3).1 Petitioner, challenging respondent's adverse determination, has invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428.2 The sole issue for decision...

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