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submitted for decision based on the stipulated administrative
record as defined in Rule 210(b)(10). Petitioner has exhausted
its administrative remedies within the Internal Revenue Service
as required by section 7428(b)(2) and Rule 210(c)(4), received a
final adverse ruling dated December 2, 1994, and invoked the
jurisdiction of this Court by a petition filed on January 12,
1995.
Unless otherwise indicated, all section references are to
the Internal Revenue Code of 1986, and all Rule references are to
the Tax Court Rules of Practice and Procedure.
Background
Petitioner was incorporated as a nonprofit corporation under
the laws of South Carolina on June 2, 1992. Petitioner is a
museum and art gallery located on the campus of Bob Jones
University (the University) in Greenville, South Carolina.
The University first opened an art gallery in 1951, and
prior to petitioner's incorporation, the art gallery was a part
of the University. The museum and art gallery have been housed
in their present location since 1965. Petitioner represents that
the museum contains “one of the greatest collections of religious
paintings and works of art in the western hemisphere.”
At one time, the University was a tax-exempt organization.
The University's exempt status was revoked, however, as a result
of a 1983 Supreme Court decision. See Bob Jones Univ. v. United
States, 461 U.S. 574 (1983). The University maintains a policy
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