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GOLDSBORO ART LEAGUE, INC. v. COMMISSIONER

Docket No. 806-80X.

75 T.C. 337 (1980)

GOLDSBORO ART LEAGUE, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 8, 1980.

Attorney(s) appearing for the Case

John C. Hine, for the petitioner.

Joseph T. Chalhoub, for the respondent.

OPINION

TIETJENS, Judge:

Respondent determined that petitioner is not exempt from Federal income tax under section 501(c)(3).1 The prerequisites for declaratory judgment having been satisfied,2 petitioner has, pursuant to section 7428, invoked the jurisdiction of this Court.

The issue3 for our determination is whether petitioner is operated exclusively for...

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