Variety Club Tent No. 6 Charities, Inc. - Page 20

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                         ___________________________________                          
               During the years in issue, Zeve and Popovic were insiders              
          with respect to petitioner; Vecchio was not.                                







                                       OPINION                                        
                           I. Status Under Sec. 501(c)(3)                             
               Section 501(a) provides that “An organization described in             
          subsection (c) * * * shall be exempt from taxation under this               
          subtitle”.7                                                                 
















               7    Exceptions from this broad rule because of secs. 502              
          (relating to feeder organization), 503 (relating to prohibited              
          transactions by certain categories of organizations), 501(b)                
          (relating to unrelated business income), and various other                  
          provisions of the Code do not appear to be issues in the instant            
          case.                                                                       

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