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H. PRIVATE BENEFIT UNDER IRC 501(c)(3)
Similarly, in Church by Mail v. Commissioner, 765 F. 2d 1387 (9th Cir. 1985), aff’g TCM 1984-349 (1984), the Tax Court found it unnecessary to consider the reasonableness of payments made by the applicant to a business owned by its officers. The 9th Circuit Court of Appeals, in affirming the Tax Court's decision, stated: 138
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