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LEVY FAMILY TRIBE FOUNDATION v. COMMISSIONER

Docket No. 4555-77X.

69 T.C. 615 (1978)

LEVY FAMILY TRIBE FOUNDATION, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 26, 1978.

Attorney(s) appearing for the Case

Charles W. Levy (an officer), for the petitioner.

James J. McGovern, for the respondent.

OPINION

DAWSON, Judge:

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

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