LEAVY, District Judge.
The issue presented in this case is whether the services performed by the employees of the plaintiff are excepted from the payment of tax liability growing out of the provisions of 26 U.S.C.A. Int.Rev.Code, § 1426(b) (8). The specific question here involved is whether the plaintiff is a corporation organized and operated as a charitable organization with no part of its income inuring to private individuals or private shareholders.
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