Gerald L. and Joy M. Zeidler - Page 6

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          served in those positions 6 or 7 years.  In her capacity as an              
          officer, Mrs. Zeidler was familiar with the operational and                 
          financial aspects of the organization.  For all of the                      
          performances, the organization sold tickets, and proceeds were              
          used to defray the expenses of putting on the performances.  Any            
          excess monies were carried over to assist in defraying the                  
          expenses of subsequent performances, which included the purchase            
          of music, supplies, robes, tuxedos, and dresses for the chorale             
          performances.  Financial records of the organization were                   
          submitted into evidence from five performances during the years             
          in question.  For the five performances, the organization had               
          gross receipts of $10,872.84 and expenses of $9,101.88.  The                
          expenses, which were itemized, do not indicate that the                     
          organization's funds were used for the benefit of any private               
          individual, and the Court so finds.  The sources of funds to the            
          organization were identified as "ticket receipts", "patron                  
          money", and "door sales".  The distinctions between these                   
          categories of receipts were not explained at trial.  At no time             
          during its existence did the organization's gross receipts in any           
          given year exceed $5,000.                                                   
               With respect to this issue, and all other issues in these              
          cases, certain general rules are applicable, one of which is that           
          respondent's determinations in a notice of deficiency are                   
          presumed correct, and the taxpayer bears the burden of proving              

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