Appellant seeks reversal of the District Court’s judgment, after trial, granting appellee a refund of income taxes for three prior years upon a finding that the appellee is exempt from federal income taxes under Int.Rev.Code of 1954, § 501 (c)(3) and (4) as either a corporation organized and operated exclusively for charitable purposes, or as a civic league or an organization “not organized for profit but operated, exclusively for the promotion of social welfare.”

In substance, appellant contends that to the extent the trial court failed to examine separately the taxpayer’s claims of exemption, the court erred in its application of the law to the facts because each section describes distinct entities entitled to exemption for distinctly different reasons. Appellant argues that: (1) Section 501(c)(3) “organized and operated exclusively for charitable purposes” means that the primary purpose of the corporation be of a charitable nature and that anything more than an insubstantial or an incidental non-eharitable purpose dictates non-exemption; and (2) under Section 501(c)(4) “not organized for profit but operated exclusively for the promotion of social welfare” means that the taxpayer must be primarily engaged in promoting the common good and general welfare of the community and that, on the basis of the applicable regulation, Treas.Reg. § 1.501(c) (4)-l(ii), a taxpayer is not primarily operated for the promotion of the general welfare if its primary activity “is carrying on a business with the general public in a manner similar to organizations which are operated for profit.” An application of these allegedly proper legal standards to the instant fact situation, appellant contends, demands the conclusion that the District Court’s finding of exemption was clearly erroneous.

Although it may appear from the foregoing that the proper legal standards were erroneously applied to the facts because the District Court appears to state the rules conversely, it is clear, nonetheless, that each of appellant’s contentions was separately and properly considered and specifically rejected.

The District Court made a quantitative comparison of the private versus the public benefits derived from the organization and operation of the plaintiff corporation. Thereby, it was determined that the “social welfare” and “charitable purpose” requirements of the two respective sections were adequately fulfilled. We cannot disagree.

Affirmed.

. Internal Revenue Code of 1954 (26 U.S.C.) : Sec. 501. Exemption from tax on corporation, certain trusts, etc. (c) List of Exempt Organizations.— The following organizations are referred to in subsection (a) : (3) Corporations, and any community chest, fund, or foundation, organized and operated exclusively for religious, charitable, scientific, testing for public safety, literary, or education purposes, or for the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any private shareholder or individual, no substantial part of the activities of which is carrying on propaganda, or otherwise attempting, to influence legislation, and which does not participate in, or intervene in (including the publishing or distributing of statements), any political campaign on behalf of any candidate for public office. (4) Civic leagues or organizations not organized for profit but operated exclusively for the promotion of social welfare, or local associations of employees, the membership of which is limited to the employees of a designated person or persons in a particular municipality, and the net earnings of which are devoted exclusively to charitable, educational, or recreational purposes.