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ORANGE COUNTY AGRICULTURAL SOCIETY, INC. v. COMMISSIONER

Docket No. 397-81"X".

55 T.C.M. 1602 (1988)

T.C. Memo. 1988-380

Orange County Agricultural Society, Inc. v. Commissioner.

United States Tax Court.

Filed August 16, 1988.

Attorney(s) appearing for the Case

Joseph B. Murphy, for the petitioners. Cheryl Choy-Weller, for the respondent.

Memorandum Opinion

JACOBS, Judge:

Respondent made an adverse determination as to petitioner's continuing tax exempt qualification under section 501(a),1 effective for tax years beginning after October 31, 1974. Petitioner challenged that determination by instituting this proceeding for a declaratory judgment under section 7428.

The ultimate issue for decision is whether petitioner (the Society) is operated exclusively...

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