FLAUM, Circuit Judge.
Living Faith, Inc. (Living Faith) appeals the Tax Court's affirmance of a determination by the Commissioner of the Internal Revenue Service (Commissioner) that Living Faith was not operated for exempt purposes within the meaning of § 501(c)(3) of the Internal Revenue Code (I.R.C.), 26 U.S.C. § 501(c)(3). This Court has jurisdiction to review the Tax Court's ruling pursuant to I.R.C. § 7482, 26 U.S.C. § 7482. Because this case...
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