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UNIVERSITY OF MARYLAND PHYSICIANS v. COMMISSIONER

Docket No. 4383-79X.

41 T.C.M. 732 (1981)

T.C. Memo. 1981-23

University of Maryland Physicians, P.A. v. Commissioner.

United States Tax Court.

Filed January 26, 1981.

Attorney(s) appearing for the Case

Frank T. Gray, 36 South Charles St., Baltimore, Maryland, and Joseph H. Langhirt, for the petitioners. Henry K.W. Woo, for the respondent.

Memorandum Opinion

FAY, Judge:

Respondent determined petitioner does not qualify for exemption from Federal income tax as an organization described in section 501(c)(3).1 Having exhausted its administrative remedies as required by section 7428(b)(2), petitioner has timely invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428(a). The issue is whether petitioner is organized and operated exclusively...

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