Health Law Keyed to Furrow
Redlands Surgical Services v. Commissioner of Internal Revenue
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Redlands Surgical Services (Plaintiff) was a nonprofit member corporation that was a parent of a hospital. Plaintiff was also a partner with for-profit businesses that operated a surgery center. Plaintiff claimed it was entitled to tax-exempt status because it's dealings with the for-profit partners had been at arm's length and because it had charitable goals. The Internal Revenue Service (Defendant) alleged that Plaintiff had given up effective control over its sole activity—the operation of the surgery center—to the for-profit partners and that this indicated a substantial nonexempt purpose, in which Plaintiff benefited private interests impermissibly. When Defendant denied tax-exempt status, Plaintiff appealed, asserting that in determining whether an organization's purposes are charitable, the critical test is the sort of conduct in which the organization is actually engaged, not whether a for-profit or not-for-profit entity has control.
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