Lowry Hosp. Ass'n v. Comm'r
United States Tax Court
Petitioner, whose principal purpose is the operation of a hospital, was organized as a nonprofit organization under Tennessee law. Petitioner was founded by a physician whose clinic is located in the hospital building. The clinic and the hospital shared their supplies and services, and most of the hospital's patients were also patients of the founding physician and his partner.
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Petitioner, whose principal purpose is the operation of a hospital, was organized as a nonprofit organization under Tennessee law. Petitioner was founded by a physician whose clinic is located in the hospital building. The clinic and the hospital shared their supplies and services, and most of the hospital's patients were also patients of the founding physician and his partner. Petitioner made a number of large unsecured loans to a nursing home which was owned by its founding physician and a trust for the benefit of his children. In 1969, petitioner paid the expenses of some of the nursing…
1Opinion of the Court
Wilbur, Judge:
Respondent has determined the following deficiencies in petitioner’s Federal income tax:
Taxable year Deficiency Taxable year Deficiency
1967 _ $18,053.06 1970 _ $20,846.86
1968 _ 19,173.47 1971 _ 13,947.87
1969 _ 8,933.94
The issues presented for our decision are (1) whether petitioner qualified as a tax-exempt organization under section 501(c)(3)1 during the years in issue and (2) whether petitioner’s tax-exempt status may be retroactively revoked for taxable years ended prior to November 7,1972.2
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly.
Petiti…
2Cases cited11 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Stevens Bros. Foundation, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- The Founding Church of Scientology v. The United StatesUnited States Court of Claims · 1969
- Stevens Bros. Foundation, Inc. v. CommissionerUnited States Tax Court · 1962
- Chattanooga Automobile Club v. Commissioner of Internal Revenue. Warren Automobile Club, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1950
6 more not listed; retrieve them via the Exa API.
3Cited by35 opinions
- Robinette v. Comm'rUnited States Tax Court · 2004
- Unitary Mission Church v. CommissionerUnited States Tax Court · 1980
- Western Catholic Church v. CommissionerUnited States Tax Court · 1979
- B.H.W. Anesthesia Foundation, Inc. v. CommissionerUnited States Tax Court · 1979
- Dumaine Farms v. CommissionerUnited States Tax Court · 1980
30 more not listed; retrieve them via the Exa API.