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METROPOLITAN COMMUNITY SERVICE, INC. v. COMMISSIONER

Docket No. 34084-86X.

53 T.C.M. 810 (1987)

T.C. Memo. 1987-240

Metropolitan Community Service, Inc. v. Commissioner.

United States Tax Court.

Filed May 11, 1987.

Attorney(s) appearing for the Case

Oscar D. Heffner (an officer), for the petitioner. Judith M. Picken and Ronald B. Weinstock, for the respondent.

Memorandum Opinion

PANUTHOS, Special Trial Judge:

Respondent's Motion to Dismiss for Lack of Jurisdiction, filed October 24, 1986, was assigned for hearing, consideration, and ruling, thereon.1

Respondent issued a final adverse determination letter to petitioner, on May 16, 1986. In the letter, dated and sent by certified mail on May 16, 1986, respondent determined that petitioner is not an organization exempt from taxation...

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