This proceeding involves a deficiency in income tax for the taxable year ended January 31, 1950, of $397.62 and a penalty of $99.41 asserted against the William L. Powell Foundation (hereinafter referred to as the petitioner).
The issues to be determined are: (1) Whether petitioner has complied with the requirements of section 101 (6) of the Internal Revenue Code during the taxable year ended January 31, 1950, and is therefore exempt from Federal income taxation as...
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