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BALT. HEALTH AND WELFARE FUND v. COMMISSIONER

Docket No. 7001-77X.

69 T.C. 554 (1978)

BALTIMORE REGIONAL JOINT BOARD HEALTH AND WELFARE FUND, AMALGAMATED CLOTHING & TEXTILE WORKERS UNION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 9, 1978.

Attorney(s) appearing for the Case

Jacob J. Edelman, for the petitioner.

James J. McGovern, for the respondent.

OPINION

DAWSON, Judge:

Respondent determined that petitioner does not qualify for exemption from Federal income tax under section 501(c)(3).1 Petitioner challenges respondent's determination and has invoked the jurisdiction of this Court for a declaratory judgment2 pursuant to section 7428. At issue is whether the petitioner served the private interests of its

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