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FARMS v. COMMISSIONER

Docket No. 13428-78X.

73 T.C. 650 (1980)

DUMAINE FARMS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 9, 1980.

Attorney(s) appearing for the Case

Frederick D. Herberich, Katharine Sanderson Heidlage, and Philip J. Sweeney III, for the petitioner.

Bernard B. Kornmehl, for the respondent.

OPINION

FAY, Judge:

Respondent determined petitioner does not qualify for exemption from Federal income tax under section 501(a)1 as an organization described in section 501(c)(3). Having exhausted its administrative remedies as required by section 7428(b)(2), petitioner has timely challenged respondent's determination and invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428(a). The...

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