- 38 -
was developing during the periods in issue. Additionally, we
conclude that petitioner reasonably relied on the advice of its
counsel that it need not file Forms 990-T for the periods in
issue. Accordingly, we hold that petitioner is not subject to
the additions to tax or penalties for any of the taxable periods
in issue.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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