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SOUND HEALTH ASSOCIATION v. COMMISSIONER

Docket No. 8144-77X.

71 T.C. 158 (1978)

SOUND HEALTH ASSOCIATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 13, 1978.

Attorney(s) appearing for the Case

William N. Mathias III, for the petitioner.

James J. McGovern, for the respondent.

OPINION

STERRETT, Judge:

This is an action for declaratory relief brought by petitioner Sound Health Association against respondent Commissioner of Internal Revenue Service under the terms of new section 7428, I.R.C. 1954. Respondent has determined that petitioner qualifies as an organization described in section 501(c)(4), but fails to qualify as an organization described in section 501(c)(3). The only issue before the Court is whether or not petitioner...

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