FEDERATION PHARMACY SERVICES v. C. I. R.

No. 79-1883.

625 F.2d 804 (1980)

FEDERATION PHARMACY SERVICES, INC., Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided July 11, 1980.


Attorney(s) appearing for the Case

Michael Trucano, Minneapolis, Minn., for appellant.

Jay W. Miller, Atty., Tax Div., App. Section, Dept. of Justice, Washington, D. C. (argued), M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Richard Farber, Washington, D. C., on brief, for appellee.

Before HENLEY and McMILLIAN, Circuit Judges, and ROY, Judge.


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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