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GONDIA CORPORATION v. COMMISSIONER

Docket No. 8713-77X.

44 T.C.M. 590 (1982)

T.C. Memo. 1982-422

Gondia Corporation v. Commissioner.

United States Tax Court.

Filed July 26, 1982.

Attorney(s) appearing for the Case

Stephen E.M. Diamond (an officer), for the petitioner. Eugene H. Ciranni, for the respondent.

Memorandum Opinion

CHABOT, Judge:*

Petitioner instituted this action pursuant to section 74281 for a declaratory judgment that it qualifies as an organization described in section 501(c)(3) which is exempt from tax under section 501(a) and that it qualifies as an organization described in section 170(c)(2). The issue for decision is whether petitioner is organized and operated exclusively for one...

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