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

30 F.3d 494 (1994)

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

United States Court of Appeals for the Third Circuit

30 F.3d 494 (1994)

Facts

The Geisinger Health Plan (GHP) (plaintiff) was a health-maintenance organization operating within the Geisinger Healthcare System (the system). Many of the system’s entities were established to promote community health by providing medical services to indigents. The Internal Revenue Service (IRS) (defendant) deemed these entities as charitable organizations exempt from paying federal income tax. GHP’s role was to contract with other entities providing medical services on behalf of its subscribers, who were required to pay a premium. The IRS denied GHP’s request to receive tax-exempt status. The matter was appealed to the United States Tax Court. The tax court affirmed. The matter was appealed to the United States Court of Appeals for the Third Circuit. The Third Circuit held that GHP was not a charitable organization but remanded the case back to the tax court with instructions to consider the applicability of the integral-part doctrine. The tax court found the integral-part doctrine inapplicable. The matter was appealed to the Third Circuit again.

Rule of Law

Issue

Holding and Reasoning (Lewis, J.)

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