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Consortium handles all resident grievances including matters of
termination of employment. Thus, even if the Consolidation
Contract grants petitioners the right to hire and fire residents,
other provisions of the contract supersede that right by
delegating substantial responsibility to the Consortium and its
members. Further, even if petitioners did have responsibility
for the program, they have no administrative employees, so it is
unclear how they would discharge this responsibility.
Petitioners have not met their burden of establishing that they
advance the education of residents.
B. Lessening the Burdens of Government
Petitioners also argue that they lessen the burdens of
Government. An organization lessens the burdens of Government if
(1) the activities undertaken are those that the Government
considers to be its burden, and (2) those activities actually
lessen such burdens. Columbia Park & Recreation Association v.
Commissioner, 88 T.C. 1, 21 (1987), affd. without published
opinion 838 F.2d 465 (4th Cir. 1988).
Petitioners have not established that the Schools and/or
hospitals constitute governmental agencies. Nor have they
established that the activities they have undertaken are those
that the Government considers its burden. Even if we assume that
petitioners had established these points, their activities do not
lessen any burdens. All of petitioners' financial support comes
from the Schools and hospitals. The cost of paying salaries and
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