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AMERICAN SCIENCE FOUNDATION v. COMMISSIONER

Docket No. 42383-84X.

52 T.C.M. 1049 (1986)

T.C. Memo. 1986-556

American Science Foundation v. Commissioner.

United States Tax Court.

Filed November 20, 1986.

Attorney(s) appearing for the Case

Stanley W. Taylor, 100 The Embarcadero, San Francisco, Calif., for the petitioner. Dianne I. Crosby, for the respondent.

Memorandum Opinion

NIMS, Judge:

Respondent has determined that petitioner does not qualify for exemption from Federal income tax under section 501(a)1 by virtue of being an organization described in section 501(c)(3). Petitioner seeks review of this decision pursuant to section 7428. The issue in this case is whether petitioner has demonstrated that it will operate exclusively in furtherance of one or more exempt purposes within...

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