Redlands Surgical Servs. v. Commissioner
United States Tax Court
P is a nonprofit corporation. Its sole activity is participating as co-general partner with a for-profit corporation in a partnership that is general partner of an operating partnership that owns and operates an ambulatory surgery center. Held: On the facts involved herein, P has ceded effective control over the operations of the partnerships and the surgery center to private parties, conferring impermissible private benefit.
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P is a nonprofit corporation. Its sole activity is participating as co-general partner with a for-profit corporation in a partnership that is general partner of an operating partnership that owns and operates an ambulatory surgery center. Held: On the facts involved herein, P has ceded effective control over the operations of the partnerships and the surgery center to private parties, conferring impermissible private benefit. P is therefore not operated exclusively for exempt purposes within the meaning of sec. 501(c)(3), I.R.C. 1986.
1Opinion of the Court
REDLANDS SURGICAL SERVICES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Redlands Surgical Servs. v. Commissioner
No. 11025-97X
United States Tax Court
113 T.C. 47; 1999 U.S. Tax Ct. LEXIS 29; 113 T.C. No. 3;
July 19, 1999, Filed
Decision will be entered for respondent.
P is a nonprofit corporation. Its sole activity is
participating as co-general partner with a for-profit
corporation in a partnership that is general partner of an
operating partnership that owns and operates an ambulatory
surgery center. Held: On the facts involved herein, P has ceded
effective control over the operations…
2Cases cited43 opinions
- Simon v. Eastern Kentucky Welfare Rights OrganizationSupreme Court of the United States · 1976
- Bob Jones University v. United StatesSupreme Court of the United States · 1983
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
- B.S.W. Group, Inc. v. CommissionerUnited States Tax Court · 1978
- Eastern Kentucky Welfare Rights Organization v. William E. Simon, Secretary of the TreasuryCourt of Appeals for the D.C. Circuit · 1974
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