McKAY, Circuit Judge.
After examining the briefs and the appellate record, this three-judge panel has determined unanimously that oral argument would not be of material assistance in the determination of this appeal. See Fed.R.App.P. 34(a); 10th Cir.R. 10(e). The cause is therefore ordered submitted without oral argument.
On August 11, 1978, the Internal Revenue Service granted The Church of World Peace tax exempt status under 26 U.S.C. § 501(c...
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