Education Athletic Association, Inc. - Page 3




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               This case was submitted on the stipulated record pursuant to           
          Rule 122.  The evidentiary facts and representations contained in           
          the administrative record are assumed to be true.  See Rule                 
          217(b)(1).                                                                  
                                     Background                                       
               At the time the petition was filed, petitioner's principal             
          office was located in Omaha, Nebraska.  Petitioner was organized            
          and incorporated on January 18, 1971, under Nebraska law as a               
          nonprofit organization primarily to promote athletic education.             
               On its Form 1023, Application for Recognition of Exemption,            
          petitioner checked section 509(a)(2) as the reason it was not a             
          private foundation.                                                         
               On August 22, 1984, the District Director issued a favorable           
          determination letter stating that petitioner was an organization            
          exempt from Federal income taxation under section 501(c)(3).  The           
          letter also stated that petitioner was reasonably expected to be            
          a publicly supported organization under sections 509(a)(1) and              
          170(b)(1)(A)(vi).  The ruling stated that petitioner would be               
          treated as a nonprivate foundation during an advance ruling                 
          period ending December 31, 1989.                                            
               Petitioner's sole source of support for its 1993, 1994, and            
          1995 years was income from the sale of pickle cards to liquor               
          establishments in Nebraska.  Pickle cards are a game of chance              
          authorized by Nebraska statute.  See Neb. Rev. Stat. secs. 9-301            
          through 9-356 (1997 & Supp. 1997).  Certain section 501(c)(3),              



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