MEMORANDUM OPINION
WELLS, Chief Judge:
In a final adverse determination letter, respondent determined that IHC Care, Inc. (petitioner), did not qualify as an organization described in sections 501(c)(3) and 170(c)(2) and was not entitled to exemption from Federal income tax pursuant to section 501(a). Unless otherwise indicated, section references are to sections of the Internal Revenue Code, as amended, and Rule references are to the Tax Court Rules of...
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