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PARATRANSIT INS. CORP. v. COMMISSIONER

Docket No. 28342-91X.

102 T.C. 745 (1994)

PARATRANSIT INSURANCE CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 14, 1994.

Attorney(s) appearing for the Case

Sam Storey, for petitioner.

Ronald B. Weinstock, for respondent.

OPINION

RAUM, Judge:

The Commissioner determined that petitioner is not an organization described in section 501(c)(3)1 and that it is not exempt from Federal income tax under section 501(a) for the taxable year 1988 and subsequent years. Petitioner has invoked the jurisdiction of this Court pursuant to section 7428 to obtain a declaratory judgment as to whether it meets the requirements...

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