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SENIOR CITIZENS OF MISSOURI, INCORPORATED v. COMMISSIONER

Docket No. 3090-87X.

56 T.C.M. 480 (1988)

T.C. Memo. 1988-493

Senior Citizens of Missouri, Incorporated v. Commissioner.

United States Tax Court.

Filed October 12, 1988.

Attorney(s) appearing for the Case

Earl S. Dean (an officer), for the petitioner.* William Miller and George J. Blaine, for the respondent.

Memorandum Findings of Fact and Opinion

POWELI, Special Trial Judge:1

Respondent determined that Senior Citizens of Missouri, Inc. (petitioner) did not qualify as an exempt organization under section 501(c)(3).2 Petitioner then brought a declaratory judgment proceeding pursuant to section 7428. The sole issue for decision is whether petitioner operated exclusively for an exempt purpose within the...

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