United States Tax Court November 3, 1981, Docket No. 4425-78X (North American Sequential Sweepstakes v. Commissioner)

lead-opinion

OPINION

Wiles, Judge:

Respondent determined that petitioner does not qualify for exemption from Federal income tax as an organization described in section 501(c)(3).1 Petitioner, challenging respondent’s adverse determination, has invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428.