Associated Hospital Services, Inc. v. Commissioner
United States Tax Court
Petitioner is an organization controlled jointly by four tax-exempt hospitals. Its sole function is to furnish laundry services to its member hospitals.
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Petitioner is an organization controlled jointly by four tax-exempt hospitals. Its sole function is to furnish laundry services to its member hospitals. Held, under the reenactment doctrine applicable to regulations and interpretations long continued without substantial change applying to unamended or reenacted statutes, and deemed to have congressional approval, petitioner is a feeder organization under sec. 502, I.R.C. 1954, and sec. 1.502-1(b), Income Tax Regs., and is therefore not exempt under sec. 501(c)(3). National Muffler Dealers Assn., Inc. v. United States, 440 U.S. 472 (1979);…
1Opinion of the Court
OPINION
Nims, Judge:
Respondent determined that (1) petitioner is a feeder organization described in section 502; (2) is not an organization described in section 501(e); and (3) therefore is not an exempt organization under section 501(c)(3).1
Petitioner has invoked the jurisdiction of this Court, pursuant to section 7428, for a declaratory judgment that it is exempt from tax under section 501(c)(3). Petitioner has satisfied the prerequisites for this declaratory judgment action: It has exhausted its administrative remedies as required under section 7428(b)(2); it is the organization the…
2Cases cited29 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
- Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
- Helvering v. WinmillSupreme Court of the United States · 1938
24 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- HCSC-Laundry v. United StatesSupreme Court of the United States · 1981
- Florida Hosp. Trust Fund v. CommissionerUnited States Tax Court · 1994
- Hcsc-Laundry v. United StatesCourt of Appeals for the Third Circuit · 1980
- Eiry Trust v. CommissionerUnited States Tax Court · 1981
- Council for Bibliographic & Information Technologies v. CommissionerUnited States Tax Court · 1992
10 more not listed; retrieve them via the Exa API.