Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined a deficiency of $179,880.00 in the petitioner's Federal income tax for its short tax year of June 1, 1976, through December 31, 1976. The only issue for decision is whether the petitioner, an exempt organization, is entitled to any deductions for expenses in computing its unrelated business taxable income attributable to the sale of advertising in its magazines.
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