IHC Health Plans, Inc. v. Commissioner of Internal Revenue
United States Court of Appeals for the Tenth Circuit
325 F.3d 1188 (2003)
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.)
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