JUNALUSKA ASSEMBLY HOUSING, INC. v. COMMISSIONER

Docket No. 2394-85X.

86 T.C. 1114 (1986)

JUNALUSKA ASSEMBLY HOUSING, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 28, 1986.


Attorney(s) appearing for the Case

Michael L. Miller, for the petitioner.

Jeremy Nowak, for the respondent.


OPINION

WILLIAMS, Judge:*

The Commissioner determined that petitioner does not qualify for exemption from Federal income taxation under section 501(a)1 as an organization described in section 501(c)(3) and that petitioner is not a "church" within the meaning of section 170(b)(1)(A)(i) for purposes of determining its status as a private foundation under...

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