Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined deficiencies in petitioner's income taxes for the taxable years ended May 31, 1958, and May 31, 1959, in the respective amounts of $74,212.58 and $247,331.07. The sole issue for decision is whether during these years the petitioner was exempt under section 501(c)(3), Internal Revenue Code of 1954, as a corporation organized and operated exclusively for religious and educational...
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