University Medical Resident Services, P.C. - Page 2

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          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 submitted for decision based on the stipulated                     
          administrative records as defined in Rule 210(b)(10).                         
          Petitioners have exhausted their administrative remedies within               
          the Internal Revenue Service as required by section 7428(b)(2)                
          and Rule 210(c)(4), received final adverse rulings dated August               
          26, 1994, and invoked the jurisdiction of this Court by petitions             
          filed on November 21, 1994.                                                   
               Unless otherwise indicated, all section references are to                
          the Internal Revenue Code, and all Rule references are to the Tax             
          Court Rules of Practice and Procedure.                                        
               Petitioners are professional service corporations organized              
          under the not-for-profit corporation law of the State of New                  
          York.  Each petitioner's principal place of business was in                   
          Buffalo, New York, at the time their respective petitions were                
               Prior to 1983, the State University of New York at Buffalo,              
          New York (the University), sponsored graduate clinical training               
          programs in medicine and dentistry.  Within the University, these             
          programs were administered by the School of Medicine and                      
          Biomedical Sciences and the School of Dental Medicine                         

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