FEDERATION PHARMACY SERVICES, INC. v. COMMISSIONER

Docket No. 4787-78X.

72 T.C. 687 (1979)

FEDERATION PHARMACY SERVICES, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 26, 1979.


Attorney(s) appearing for the Case

Michael Trucano, for the petitioner.

Kevin M. Bagley, for the respondent.


OPINION

STERRETT, Judge:

Respondent determined that petitioner does not qualify for exemption from Federal income tax under section 501(c)(3). Petitioner challenges respondent's determination and has invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428. The issue is whether petitioner is organized and operated exclusively for charitable purposes within the meaning of section 501(c)(3).

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