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QUARRIE CHARITABLE FUND v. COMMISSIONER

Docket No. 6837-77X.

70 T.C. 182 (1978)

WILLIAM F., MABLE E., AND MARGARET K. QUARRIE CHARITABLE FUND, THE NORTHERN TRUST COMPANY, TRUSTEE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 8, 1978.

Attorney(s) appearing for the Case

William P. Sutter, James R. Hellige, and Francis O. McDermott, for the petitioner.

Byron J. Furseth, for the respondent.

TANNENWALD, Judge:

Respondent determined that petitioner is a private foundation as defined in section 509(a).1 Petitioner brought an action under section 7428 for a declaratory judgment that it is not a private foundation because it is an organization described in section 509(a)(3).

OPINION

This case was submitted upon the basis of the pleadings and the facts recited in...

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