ROY, District Judge.
This is an appeal by the Federation Pharmacy Services, Inc., (Federation) from the decision of the United States Tax Court that it is not a tax-exempt organization as described in § 501(c)(3) of the Internal Revenue Code of 1954. Timely notice of appeal was filed and jurisdiction of this Court is based upon § 7482(a) of the Internal Revenue Code of 1954 (26 U.S.C.).
This case was submitted to the Tax Court for decision on a stipulated...
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