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B.S.W. GROUP, INC. v. COMMISSIONER

Docket No. 6646-77X.

70 T.C. 352 (1978)

B.S.W. GROUP, INCORPORATED, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 30, 1978.

Attorney(s) appearing for the Case

Edward L. Williams (an officer), for the petitioner.

Kevin M. Bagley, for the respondent.

OPINION

RAUM, Judge:

Respondent determined that petitioner does not qualify for exemption from Federal income tax under section 501(c)(3), I.R.C. 1954. Petitioner challenges respondent's determination and has invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428.1 The issue is whether petitioner is operated exclusively for charitable, educational...

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