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UNIVERSITY MEDICAL RESIDENT SERVICES, P.C. v. COMMISSIONER

Docket Nos. 21401-94X, 21402-94X.

71 T.C.M. 3130 (1996)

T.C. Memo. 1996-251

University Medical Resident Services, P.C., v. Commissioner. University Dental Resident Services, P.C., v. Commissioner.

United States Tax Court.

Filed May 30, 1996.

Attorney(s) appearing for the Case

Lawrence M. Ross, Buffalo, N.Y., for the petitioners. Joan Ronder Domike, for the respondent.

MEMORANDUM OPINION

FOLEY, Judge:

Petitioners, University Medical Resident Services, P.C. (UMRS), and University Dental Resident Services, P.C. (UDRS), seek a declaratory judgment under section 7428(a) that they are exempt from Federal income taxation under section 501(a) as organizations meeting the requirements of section 501(c)(3). Although they filed separate petitions, these cases were consolidated under Rule 141(a). Pursuant to Rule 122, the cases were...

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