New Jersey Council Of Teaching Hospitals v. Commissioner

149 T.C. No. 22

UNITED STATES TAX COURT NEW JERSEY COUNCIL OF TEACHING HOSPITALS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2822-16. Filed December 20, 2017. P is a tax-exempt charitable organization described in I.R.C. sec. 501(c)(3) whose exempt purposes include promoting health care and medical education. During its calendar tax years 2004-2007, P contracted with third-party vendors, V1 and V2, to provide its mem- bers (hospitals and a medical school) access to debt-collection serv- ices and group purchasing programs. P received fees from V1 and V2 in exchange…