- 2 - 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. Background 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 filed. 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 MedicinePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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