University Medical Resident Services, P.C. - Page 14

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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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