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TEXAS LEARNING TECH. GROUP v. COMMISSIONER

Docket No. 18585-89X.

96 T.C. 686 (1991)

TEXAS LEARNING TECHNOLOGY GROUP, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 30, 1991.

Attorney(s) appearing for the Case

Leonard J. Henzke, Jr., and William J. Lehrfeld, for the petitioner.

Ronald B. Weinstock, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent denied petitioner's application for recognition as a nonprivate foundation within the meaning of section 509(a)(1).1 The issue for decision is whether petitioner qualifies as a nonprivate foundation under section 509(a)(1) because it is a political subdivision of a State as described in section 170(b)(1)(A)(v) and (c)(1).2...

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