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N.J. COUNCIL OF TEACHING HOSPS. v. COMMISSIONER

Docket No. 2822-16.

149 T.C. 466 (2017)

149 T.C. No. 22

NEW JERSEY COUNCIL OF TEACHING HOSPITALS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 20, 2017.

Attorney(s) appearing for the Case

T. J. Sullivan and Joseph A. Rillotta , for petitioner.

Joan Casali and Mark L. Hulse , for respondent.

OPINION

With respect to petitioner's calendar tax years 2004, 2005, 2006, and 2007, the Internal Revenue Service (IRS or respondent) determined deficiencies in unrelated business income tax (UBIT) under section 511(a)(1) as follows:1



                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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