At issue in this proceeding is whether petitioner is entitled to State tax deductions for contributions he made to Scarborough School, Inc. (hereinafter the school), during the years 1979 and 1980. The school was granted Federal tax-exempt status as an educational institution in 1943. From 1943 to October 1978 the school was listed in Internal Revenue Service Publication No. 78 (hereinafter Publication No. 78), which lists approved organizations...
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