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St. David's Health Care System, Inc. v. United States

2002 U.S. Dist. LEXIS 10453 (2002)

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St. David’s Health Care System, Inc. v. United States

United States District Court for the Western District of Texas
2002 U.S. Dist. LEXIS 10453 (2002)

Facts

St. David’s Health Care System, Inc. (St. David’s) (plaintiff) was a tax-exempt organization that operated hospitals in Texas. St. David’s entered into a partnership with a for-profit business, HCA Healthcare Corporation (HCA), and contributed its hospitals to the partnership. St. David’s and HCA were each allotted an equal number of appointees to the partnership’s governing board. However, St. David’s had exclusive power to appoint the chairman of the board. Moreover, the governing documents of the partnership bound the partnership to operate all its hospitals to benefit the community. The Internal Revenue Service (defendant) revoked the tax-exempt status of St. David’s due to the partnership with HCA. St. David’s sued to have its tax-exempt status reinstated.

Rule of Law

Issue

Holding and Reasoning (Nowlin, C.J.)

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Casebooks

Taxation of Nonprofit and Exempt Organizations

Key Terms