Salvation Navy, Inc. - Page 1

                                 T.C. Memo. 2002-275                                  

                               UNITED STATES TAX COURT                                

                SALVATION NAVY, INC., Petitioner v. COMMISSIONER OF                   
                            INTERNAL REVENUE, Respondent                              

               Docket No.  7013-01X.             Filed October 30, 2002.              

                    Based upon the facts contained in the                             
               administrative record, Held:  Petitioner is not                        
               operated as an organization entitled to exemption under                
               sec. 501(c)(3), I.R.C.                                                 

               David A. Valfer (an officer), for petitioner.                          
               Linda P. Azmon, for respondent.                                        

                                 MEMORANDUM OPINION                                   
               NIMS, Judge:  Respondent determined that petitioner                    
          Salvation Navy, Inc. (SNI), does not qualify as a section                   

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