IHC Health Plans, Inc. v. Commissioner
United States Tax Court
T.C. Memo. 2001-246 (2001)
- Written by Daniel Clark, JD
Facts
IHC Health Plans, Inc. (IHC) (plaintiff) was a health maintenance organization (HMO) enrolling approximately half of Utah’s Medicaid-eligible residents and approximately 20 percent of Utah’s total population. IHC offered large group-employer plans, small group-employer plans, and individual plans, all with different premium-calculation schemes. The offered plans covered a wide variety of prices, and IHC had generally open enrollment policies. IHC did not, however, provide care for nonenrollees. IHC did not own its own medical facilities or employ its own physicians. Rather, IHC contracted with Health Services, a tax-exempt IHC affiliate that operated medical facilities, or independent hospitals to provide enrollees with medical care. Enrollees received approximately 20 percent of their care from Health Services’ physicians. The Internal Revenue Service (IRS) (defendant) determined that IHC did not qualify for exemption from federal income tax under § 501(c)(3) of the Internal Revenue Code. IHC filed a petition with the United States Tax Court challenging the IRS’s determination.
Rule of Law
Issue
Holding and Reasoning ()
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