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CALLAWAY FAMILY ASSOCIATION, INC. v. COMMISSIONER

Docket No. 554-78X.

71 T.C. 340 (1978)

THE CALLAWAY FAMILY ASSOCIATION, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 5, 1978.

Attorney(s) appearing for the Case

Bruce R. Hopkins, for the petitioner.

Byron J. Furseth, for the respondent.

OPINION

WILBUR, Judge:

Respondent determined that petitioner did not qualify for exemption from Federal income tax under section 501(a) as an organization described in section 501(c)(3).1 Petitioner challenges respondent's determination and has invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428.2 The issue for...

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