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ANCLOTE PSYCHIATRIC CENTER v. COMMISSIONER

Docket No. 19530-91X.

98 T.C. 374 (1992)

ANCLOTE PSYCHIATRIC CENTER, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 31, 1992.

Attorney(s) appearing for the Case

James D. O'Donnell, Keith H. Johnson, and V. Jean Owens, for petitioner.

Vivian A. Moore and Henry G. Salamy, for respondent.

OPINION

WRIGHT, Judge:

This matter is before the Court on respondent's motion to dismiss petitioner's petition for declaratory judgment filed pursuant to section 74281 on the basis that we lack jurisdiction. For the reasons set forth herein, we hold that the Court has jurisdiction over this matter and that respondent's motion to dismiss petitioner's petition for declaratory judgment must be denied.

Petitioner is...

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