T.C. Memo. 2001-247
UNITED STATES TAX COURT
IHC GROUP, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14599-99X. Filed September 19, 2001.
Douglas M. Mancino, James L. Malone III, and Robert C.
Louthian III, for petitioner.
Mark A. Weiner, Kirk M. Paxson, Don R. Spellman, and Kenneth
M. Griffin, for respondent.
MEMORANDUM OPINION
WELLS, Chief Judge: In a final adverse determination
letter, respondent determined that IHC Group, Inc. (petitioner),
did not qualify as an organization described in sections
501(c)(3) and 170(c)(2) and was not entitled to exemption from
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