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WARREN M. GOODSPEED SCHOLARSHIP FUND v. COMMISSIONER

Docket No. 6725-77X.

70 T.C. 515 (1978)

WARREN M. GOODSPEED SCHOLARSHIP FUND, BAYBANK MERCHANTS, N.A., TRUSTEE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 15, 1978.

Attorney(s) appearing for the Case

George W. Butterworth III and Francis W. Dubreuil, for the petitioner.

Bernard B. Kornmehl, for the respondent.

OPINION

RAUM, Judge:

The Commissioner determined that petitioner is a private foundation as defined in section 509(a), I.R.C. 1954. The petitioner has invoked the jurisdiction of this Court, pursuant to section 7428,1 for a declaratory judgment that it is an organization described in section 509(a)(3) and therefore not a private foundation. The only question is whether petitioner satisfies the organizational test set forth...

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