T.C. Memo. 1997-424                                                                       
                                     UNITED STATES TAX COURT                                          
                           KJ'S FUND RAISERS, INC., Petitioner v.                                     
                        COMMISSIONER OF INTERNAL REVENUE, Respondent                                  
                  Docket No. 10279-96X.              Filed September 22, 1997.                        
                  Stephen S. Ankuda, for petitioner.                                                  
                  Ronald B. Weinstock, for respondent.                                                
                                        MEMORANDUM OPINION                                            
                  RAUM, Judge:  The Commissioner determined that petitioner                           
            did not meet the section 501(c)(3)1 requirements for                                      
            qualification as an exempt organization, with the consequence                             
                  1  Unless otherwise indicated, all section references are to                        
            the Internal Revenue Code in effect for the years at issue, and                           
            all Rule references are to the Tax Court Rules of Practice and                            
            Procedure.                                                                                
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