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CHART, INC. v. UNITED STATES

Civ. A. No. 79-0836.

491 F.Supp. 10 (1979)

CHART, INC., Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, District of Columbia.

December 4, 1979.

Attorney(s) appearing for the Case

Jack A. Overton, Jr., Robert S. Bernard, Albany, N.Y., Lawrence D. Wasko, Seamon, Wasko & Ozment, Washington, D.C., for plaintiff.

John J. McCarthy, Donald J. Gavin, Robert L. Gordon, Tax Division, U.S. Dept. of Justice, Washington, D.C., for defendant.

MEMORANDUM OPINION

CHARLES R. RICHEY, District Judge.

This action presents to the Court a question of first impression: whether an organization which qualifies under section 501(e) of the Internal Revenue Code of 1954 [hereinafter, "the Code"], which is the tax-exemption provision enacted by Congress specifically for cooperative hospital service organizations, may also qualify under section 501(c)(3) of the Code, which is the general provision for tax-exempt...

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