3
and (2) whether petitioners' charitable expenditures are fully
deductible as business expenses under section 512.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated by this reference. Each of the petitioners
conducted its principal activities in the State of Texas at the
time its petition was filed.
WMPI is an unincorporated association recognized by the
Internal Revenue Service (IRS) as exempt from taxation under
section 501(c)(6). FSEP, Schoenstatt, ACADA, and WSA are non-
profit corporations incorporated under the laws of the State of
Texas and are recognized by the IRS as exempt from taxation under
section 501(c)(3). Each of the petitioners was recognized as
exempt during the years in issue.
During the years in issue, petitioners were licensed by the
State of Texas to conduct bingo activities. Thus, each was
authorized to conduct bingo and "instant bingo" under the Bingo
Enabling Act (the Act), Tex. Rev. Civ. Stat. Ann. art. 179d (West
1987 & Supp. 1990), and each was in compliance with the Act.
Until 1990, the Texas Comptroller of Public Accounts was
responsible for the regulation of bingo. As of January 1, 1990,
the regulation of bingo was transferred to the Texas Alcoholic
Beverage Commission.
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