Docket No. 15777-94.

72 T.C.M. 578 (1996)

T.C. Memo. 1996-406

Thwaites Terrace House Owners Corp. v. Commissioner.

United States Tax Court.

Filed September 3, 1996.

Attorney(s) appearing for the Case

Terrence J. Dwyer, Bronxville, N.Y., for the petitioner.1 Andrew J. Mandell, for the respondent.


COLVIN, Judge:

Respondent determined deficiencies in petitioner's Federal income tax of $8,117 for 1989 and $6,606 for 1990.

The issues for decision are:

1. Whether petitioner, a housing cooperative under section 216, is subject to subchapter T (sections 1381-1388), as petitioner contends, or is a membership organization under section 277, as respondent contends. We hold that petitioner is subject to subchapter T and is...

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