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OHIO TEAMSTERS EDUC. & SAFETY TRAINING TRUST FUND v. C.I.R.

No. 81-1691.

692 F.2d 432 (1982)

OHIO TEAMSTERS EDUCATIONAL AND SAFETY TRAINING TRUST FUND, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided November 8, 1982.

Attorney(s) appearing for the Case

Michael P. Mahoney, Knepper, White, Arter & Hadden, Columbus, Ohio, for petitioner-appellant.

Kenneth W. Gideon, Chief Counsel, I.R.S., John F. Murray, Michael L. Paup, Glenn L. Archer, Jr., Robert A. Bernstein, Michael J. Roach, Tax Div., Dept. of Justice, Washington, D.C., for respondent-appellee.

Before KENNEDY and KRUPANSKY, Circuit Judges, and RUBIN, District Judge.

KRUPANSKY, Circuit Judge.

This is an appeal by the Ohio Teamsters Educational and Safety Training Trust Fund (Fund) from a decision of the United States Tax Court entered August 4, 1981 which upheld a decision by the Commissioner of Internal Revenue (IRS) that the Fund did not qualify for an exemption pursuant to 26 U.S.C. § 501(c)(3) as a charitable organization.

The Fund was organized in 1976 pursuant to a collective bargaining agreement between the...

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