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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.
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 Medicine
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