Health Law Keyed to Furrow
IHC Health Plans, Inc. v. Commissioner of Internal Revenue (I)
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Intermountain Health Care (IHC) formed a subsidiary, IHC Health Services (Health Services), as a Utah non-profit corporation. Health Services operated twenty-two hospitals in Utah and Idaho, and during the years of 1997 through 1999, Health Services provided $1.2 billion in unreimbursed medical care to Medicaid patients and another $91 million in unreimbursed care to indigent patients. The Commissioner of Internal Revenue (Commissioner) (Defendant) recognized Health Services as having tax-exempt status under § 501(c)(3). Later, IHC formed three additional subsidiary health care companies: IHC Health Plans (Health Plans) (Plaintiff), IHC Care, Inc. (Care) and IHC Group, Inc. (Group) to operate as health maintenance organizations (HMOs). The Commissioner (Defendant) would later conclude that, pursuant to § 501(c)(3), none of these three subsidiaries was operating exclusively for exempt purposes. The Defendant revoked Plaintiff's exempt status and determined that Care and Group were not entitled to the exemption. Health Plans (Plaintiff), Care and Group brought suit in the United States Tax Court seeking a declaratory judgment to reverse Defendant's ruling. The Tax Court affirmed the Defendant's ruling in a separate opinion for each of the three corporate entities. Plaintiff became the successor in interest to Care and Group and brings this appeal on behalf of all three entities.
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