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SYRANG AERO CLUB, INC. v. COMMISSIONER

Docket No. 13244-78X.

73 T.C. 717 (1980)

SYRANG AERO CLUB, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 17, 1980.

Attorney(s) appearing for the Case

John M. Lischak, for the petitioner.

Richard S. Kestenbaum and Bernard B. Kornmehl, for the respondent.

OPINION

TIETJENS, Judge:

Respondent determined that petitioner does not qualify for exemption from Federal income tax under section 501(c)(3).1 Petitioner, challenging respondent's adverse determination, has invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428.

The issue for our determination is whether petitioner is organized and operated exclusively for one or more exempt...

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