From our private database of 39,700+ case briefs...
Harding Hospital, Inc. v. United States
United States Court of Appeals for the Sixth Circuit
505 F.2d 1068 (1974)
Harding Hospital, Inc. (Harding) (plaintiff) was a teaching hospital that used a specialized therapy style to treat psychiatric patients. Originally a for-profit hospital, Harding later amended its articles of incorporation to become a tax-exempt nonprofit organization. Harding contracted with Harding-Evans Medical Associates, Inc. (HEMA), a group of seven specific doctors, to treat 90 to 95 percent of Harding’s patients. HEMA received payment for treating those patients. After converting to a nonprofit, Harding also paid HEMA an annual amount to provide supervision and other services to the hospital, including teaching residents and providing free or reduced-rate care to Harding’s indigent patients. HEMA paid Harding a monthly fee to rent equipment and office space. Although the fee amount went up and down, HEMA paid Harding an amount well below market value for these rentals for several years. The federal government (defendant) determined that Harding did not qualify for a nonprofit tax exemption, and Harding was forced to pay taxes. Harding sued to recover the taxes, but the district court ruled that Harding did not qualify for a nonprofit tax exemption. Harding appealed.
Rule of Law
Holding and Reasoning (Phillips, C.J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 645,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.Learn about our approachRead more about Quimbee
Here's why 645,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 39,700 briefs, keyed to 988 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.