MEMORANDUM OPINION
COLVIN, Judge:
Respondent determined deficiencies in petitioner's Federal income tax of $8,117 for 1989 and $6,606 for 1990.
The issues for decision are:
1. Whether petitioner, a housing cooperative under section 216, is subject to subchapter T (sections 1381-1388), as petitioner contends, or is a membership organization under section 277, as respondent contends. We hold that petitioner is subject to subchapter T and is...
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