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time in the past had applied with the Internal Revenue Service
(IRS) for recognition as a tax-exempt organization under section
501(c)(3); however, no determination was ever made by the IRS
that the organization was a qualified organization under section
501(c)(3). The parties stipulated that the organization was not
listed as a tax-exempt nonprofit organization on the U.S.
Department of Treasury Cumulative List of organizations pursuant
to section 501(c). The organization never pursued its
application for recognition as an organization exempt under
section 501(c)(3). In the notices of deficiency, respondent
disallowed the contributions for the 3 years.
At the time of trial, the organization had been in existence
approximately 15 years. It was made up of volunteer singers,
numbering approximately 45, from Greendale, Wisconsin, and its
environs who were interested in furthering the enjoyment of music
in the community and who, in general, "loved to sing". The
organization had two public performances each year, one in the
spring and one near Christmas. Mrs. Zeidler was secretary of the
organization and also served on its executive board, having
3(...continued)
for 1992 is stated to be $193. At trial, counsel for respondent
acknowledged that amount to be in error and that the correct
amount was $143. Respondent agrees that the amounts at issue for
the 3 years were in fact paid by petitioners and that
disallowance of the deduction was based solely on respondent's
determination that the organization was not an exempt charitable
organization under sec. 501(c)(3).
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