United States Tax Court July 26, 1979, Docket No. 4787-78X (Federation Pharmacy Services, Inc. v. Commissioner)

lead-opinion

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.