IHC Health Plans, Inc. v. Commissioner of Internal Revenue
United States Court of Appeals for the Tenth Circuit
325 F.3d 1188 (2003)
- Written by Craig Conway, LLM
Facts
Intermountain Health Care, Inc. (IHC) (plaintiff) formed IHC Health Services (Health Services), a non-profit corporation that operated 22 hospitals in Utah and Idaho and provided nearly $1.2 billion in medical services to paying patients and $91 million in free health care services between 1997 and 1999. The Commissioner of Internal Revenue (Commissioner) (defendant) recognized Health Services as a tax-exempt organization under 26 U.S.C. § 501(c)(3). Health Services then formed three entities, IHC Health Plans, IHC Care, and IHC Group, to operate as health maintenance organizations. The Commissioner denied the three entities tax-exempt status under § 501(c)(3), revoking Health Plans' tax-exempt status retroactively. IHC Health Plans, IHC Care, and IHC Group, brought suit against the Commissioner in U.S. Tax Court seeking a declaratory judgment reversing the Commissioner’s determinations. The court denied the declaratory judgment. The three entities appealed to the court of appeals.
Rule of Law
Issue
Holding and Reasoning (Tacha, J.)
What to do next…
Here's why 805,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 46,300 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.
