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SPIRITUAL OUTREACH SOCIETY v. COMMISSIONER

Docket No. 23387-87X.

58 T.C.M. 1284 (1990)

T.C. Memo. 1990-41

Spiritual Outreach Society v. Commissioner.

United States Tax Court.

Filed January 23, 1990.

Attorney(s) appearing for the Case

Michael A. Markenson, 7777 Bonhomme, St. Louis, Mo., for the petitioner. William I. Miller, for the respondent.

Memorandum Opinion

TANNENWALD, Judge:

Respondent determined that Spiritual Outreach Society (petitioner) was a private foundation within the meaning of section 509(a).1 Having exhausted its administrative remedies, petitioner is before this Court, pursuant to section 7428, seeking a declaratory judgment as to the correctness of respondent's action. The issues for decision are whether respondent properly determined that petitioner...

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