U. OF MASS. MED. SCHOOL GROUP PRACT. v. COMMISSIONER

Docket No. 2710-79X.

74 T.C. 1299 (1980)

UNIVERSITY OF MASSACHUSETTS MEDICAL SCHOOL GROUP PRACTICE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 16, 1980.


Attorney(s) appearing for the Case

David M. Donaldson and Carolyn N. Osteen, for the petitioner.

Henry K. W. Woo, for the respondent.


OPINION

WILBUR, Judge:

Respondent determined that petitioner does not qualify for exemption from Federal income tax under section 501(c)(3).1 Petitioner challenges respondent's determination and has invoked jurisdiction of this Court for a declaratory judgment under section 7428. The statutory prerequisities for declaratory judgment have been satisfied.2 The issue for our decision is whether...

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