MEMORANDUM OPINION
WELLS, Chief Judge.
In a final adverse determination letter, respondent determined that IHC Health Plans, Inc. (petitioner) did not qualify as an organization described in sections 501(c)(3) and 170(c)(2) and revoked petitioner's exemption from Federal income taxation pursuant to section 501(a). The revocation was retroactive to January 1, 1987. Unless otherwise indicated, section references are to sections of the Internal Revenue Code...
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