- 26 -
Park and Recreation Association v. Commissioner, 88 T.C. at 13;
sec. 1.501(c)(3)-1(a)(1), Income Tax Regs. Respondent has
prevailed on all three grounds for disqualification. Thus, we
hold that respondent’s determination that petitioner does not
qualify for tax-exempt status under section 501(c)(3) was not
erroneous and that respondent is entitled to summary judgment.
To reflect the foregoing,
An order granting respondent’s
Motion For Summary Judgment and
decision for respondent will be
entered.
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Last modified: March 27, 2008