Redlands Surgical Services v. Commissioner of Internal Revenue
United States Tax Court
113 T.C. 47 (1999)
Redlands Surgical Services (RSS) (plaintiff) was a nonprofit corporation owned by RHS Corp., a nonprofit public benefit corporation that also owned Redlands Community Hospital, a tax-exempt nonprofit entity. Surgical Care Affiliates, Inc. (SCA) was a for-profit, public corporation that owned two subsidiaries: Redlands-Centers and Redlands Management. RSS partnered with Redlands-Centers to establish a “General Partnership” and the “General Partnership” was also partnered with Inland Surgery Center Limited Partnership to create the “Operating Partnership.” Thereafter, RSS applied to the Internal Revenue Service (defendant) (IRS) for tax-exempt status. The IRS denied RSS’s application stating, “basically, all you have done is invest in a for-profit entity, Inland, and transfer the profits from this investment to your parent.”
Rule of Law
Holding and Reasoning (Thornton, 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 97,000 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.
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 166,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 13,800 briefs, keyed to 187 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.