Deer Park Country Club - Page 14

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          exempt function, the fact remains that Congress enacted a                   
          nonrecognition provision that is limited to a narrowly defined              
          set of circumstances.  The benefits of section 512(a)(3)(D) are             
          limited to gains realized on the sale of property that is used              
          directly in the performance of the organization's exempt                    
          function.  Petitioner has failed to demonstrate that the gain               
          that it realized on the sale of the 11 homesites fits within the            
          terms of section 512(a)(3)(D).  Moreover, we are not satisfied              
          that the legislative history relied upon by petitioner rises to             
          the level of unequivocal evidence of legislative purpose                    
          sufficient to ignore the literal terms of the controlling                   
          statute.  Accordingly, we agree with respondent that petitioner             
          was obligated to recognize and report the gain on its 1987 tax              
          return.                                                                     
               We have considered petitioner's remaining arguments and find           
          them unpersuasive.  To reflect the foregoing,                               
          Decision will be entered                                                    
          for respondent.                                                             















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