T.C. Memo. 1997-518
UNITED STATES TAX COURT
WOMEN OF THE MOTION PICTURE INDUSTRY, ET AL.,1 Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 11227-96, 11581-96, Filed November 17, 1997.
11918-96, 11919-96,
11921-96.
Ronald E. Ingalls, for petitioners.
Christina D. Moss, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge: This case was heard
pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.2
1 Cases of the following petitioners are consolidated herewith
for purposes of trial, briefing and opinion: Family Service of
El Paso, Inc., docket No. 11581-96; Schoenstatt, Inc., docket No.
11918-96; Amarillo Council on Alcoholism and Drug Abuse, docket
No. 11919-96; and Waldorf School Association of Texas, Inc.,
docket No. 11921-96.
2 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
(continued...)
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