Memorandum Findings of Fact and Opinion
EKMAN, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the year ending March 31, 1976, in the amount of $647.66 and an addition to tax under section 6651(a)(1) in the amount of $161.91. The issues for decision are (1) whether petitioner, an organization exempt from income tax pursuant to section 501, I.R.C. 1954, had unrelated trade or business taxable income within the meaning of sections...
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