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PARKER v. C. I. R.

Nos. 18238, 18239.

365 F.2d 792 (1966)

Merle E. PARKER, the Foundation for Divine Meditation, Incorporated, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. Merle E. PARKER, Respondent.

United States Court of Appeals Eighth Circuit.

September 9, 1966.

Attorney(s) appearing for the Case

Dr. Merle E. Parker, pro se.

Thomas Silk, Atty., Dept. of Justice, Washington, D. C., for Commissioner of Internal Revenue; Richard M. Roberts, Acting Asst. Atty. Gen., Lee A. Jackson and Gilbert E. Andrews, Attys., Dept. of Justice, Washington, D. C., on the brief.

Before VAN OOSTERHOUT, BLACKMUN and GIBSON, Circuit Judges.

GIBSON, Circuit Judge.

This case is before us on a joint petition to review a decision of the Tax Court. T.C. Memo. 1965-77. The corporate petitioner is an organization known as the Foundation for Divine Meditation (F.D.M.) and the individual petitioner is the Reverend Dr. Merle E. Parker, the founder, director, and prime functionary of F.D.M.

In 1954 F.D.M. filed an application for exemption from taxation under §...

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