TIMBERS, Circuit Judge:
Appellant, the United States, appeals from a summary judgment entered in the District of Connecticut, Peter C. Dorsey, District Judge, finding appellees exempt from taxation because their pension plan qualifies as a labor organization under Internal Revenue Code (Code) § 501(c)(5).
Appellant asserts that the type of trust here involved can neither be considered a labor organization for the purposes of § 501(c)(5), nor...
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