Revenue Ruling 83-157
Internal Revenue Service
1983-2 C.B. 94 (1983)
- Written by Daniel Clark, JD
Facts
In Revenue Ruling 69-545, the Internal Revenue Service (IRS) described a hypothetical hospital (Hospital A) that qualified for tax-free treatment. The IRS cited specific characteristics of Hospital A in support of the tax-free designation, including governance by a board of community members, open access to Hospital A’s facilities to qualified area physicians, treatment of patients on Medicare and Medicaid, and, notably, operation of an emergency room in which no patient would be denied treatment regardless of ability to pay. Guidance was sought from the IRS as to whether a hospital identical to Hospital A in all respects except that it did not operate an emergency room could still qualify for tax-exempt status. In particular, the IRS considered whether such a hospital could qualify for tax-exempt status if a state agency had determined that the hospital’s operation of an emergency room would be redundant in light of alternate and adequate emergency services already available from other providers in the hospital’s community.
Rule of Law
Issue
Holding and Reasoning ()
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