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AMERICAN CAMPAIGN ACADEMY v. COMMISSIONER

Docket No. 4787-88X.

92 T.C. 1053 (1989)

AMERICAN CAMPAIGN ACADEMY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 16, 1989.

Attorney(s) appearing for the Case

Gerald H. Sherman and Deborah M. Beers, for the petitioner.

Henry G. Salamy and Joan R. Domike, for the respondent.

OPINION

NIMS, Chief Judge:

Petitioner seeks a declaratory judgment under section 7428(a)1 that it is exempt from Federal income taxation under section 501(a) as an organization meeting the requirements of section 501(c)(3). Further, should we declare petitioner to satisfy the requirements of section 501(c)(3), we are requested to also determine whether petitioner is classified as "other than a private foundation" by reason...

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