OPINION.
TURNER, Judge:
The respondent determined deficiencies in income tax against the petitioner for the years 1937, 1938, and 1939 in the respective amounts of $5,676.12, $3,308.56, and $1,732.18. By stipulation of the parties, "The sole issue to be decided by the Court in this proceeding is whether the petitioner is an `exempt' corporation within the purview of section 101 (11) of the Revenue Acts of 1936, 1938, and the Internal Revenue Code...
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