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Geisinger Health Plan v. Commissioner of Internal Revenue (Geisinger I)

985 F.2d 1210 (1993)

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Geisinger Health Plan v. Commissioner of Internal Revenue (Geisinger I)

United States Court of Appeals for the Third Circuit

985 F.2d 1210 (1993)

Facts

The Geisinger Health Plan (GHP) (plaintiff) was one of several health-maintenance organizations that operated within the Geisinger Healthcare System. GHP served rural communities within Pennsylvania and operated by contracting with other entities to provide medical services to its subscribers. GHP’s subscribers consisted of individuals and groups who paid a premium to enroll in GHP’s plan. GHP intended to establish a subsidized-dues program, under which GHP would subsidize subscribers unable to afford the premium. GHP also intended to enroll into the plan individuals on Medicare and Medicaid. GHP established itself as a nonprofit and applied to the Internal Revenue Service (IRS) (defendant) for a charitable tax exemption under Internal Revenue Code § 501(c)(3). GHP argued that it was entitled to exemption because it promoted health in the community and because it was an integral entity within the Geisinger Healthcare System. The IRS denied GHP’s request on the ground that GHP did not operate itself as a charitable entity that provided a benefit to the public. GHP filed an action in the United States Tax Court for a declaratory judgment regarding its charitable tax-exempt status. The tax court reversed. The IRS appealed to the United States Court of Appeals for the Third Circuit.

Rule of Law

Issue

Holding and Reasoning (Lewis, J.)

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