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FLORIDA HOSP. TRUST FUND v. COMMISSIONER

Docket Nos. 2966-93X, 2967-93X, 2968-93X.

103 T.C. 140 (1994)

FLORIDA HOSPITAL TRUST FUND, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 4, 1994.

Attorney(s) appearing for the Case

Joseph J. Van Heyde II and W. Michael Clifford, for petitioners.

Charles B. Burnett, for respondent.

OPINION

NIMS, Judge:

Respondent determined that Florida Hospital Trust Fund, Florida Hospital Excess Trust Fund B, and Florida Hospital Workers' Compensation Self-Insurance Fund (petitioners) do not qualify as organizations described in section 501(c)(3), and thus are not exempt from Federal income taxation under section 501(a). (Unless otherwise indicated, all section references are to sections of the Internal Revenue Code, and all Rule references...

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