Quimbee logo
DMCA.com Protection Status
From our private database of 16,900+ case briefs...

IHC Health Plans, Inc. v. Commissioner of Internal Revenue

United States Court of Appeals for the Tenth Circuit
325 F.3d 1188 (2003)


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) and retroactively revoked Health Services’ tax-exempt status. 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


Holding and Reasoning (Tacha, J.)

What to do next…

  1. 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 453,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.

  2. 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. Read more about Quimbee.

Here's why 453,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 16,900 briefs, keyed to 226 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.

Questions & Answers

Have a question about this case?

Sign up for a free 7-day trial and ask it

Sign up for a FREE 7-day trial