Memorandum Findings of Fact and Opinion
FAY, Judge:
The Commissioner determined deficiencies in the petitioner's income and excess profits taxes, as follows:
Year Amount 1951 ................. $36,917.60 1952 ................. 15,109.79 1953 ................. 16,706.36
The only issue for decision is whether, during the years in issue, the petitioner was an organization exempt from tax...
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