Legal Opinion

Carle Foundation, an Illinois Not for Profit Corporation v. United States

Court of Appeals for the Seventh Circuit

Decided February 1, 1980No. 79-1273PublishedCited by 26 opinions

1Opinion of the Court

SPRECHER, Circuit Judge.

The question raised in this appeal is whether the sales by a tax-exempt hospital pharmacy to a nonexempt clinic and to the clinic’s private patients give rise to unrelated business taxable income. We hold that they do and therefore reverse the judgment of the lower court.

I

The Carle Foundation, which is composed of the Carle Foundation Hospital and the Carle Foundation Pharmacy, has been ex empt from federal income taxes since 1949 under 26 U.S.C. § 501(c)(3) and its predecessor statute. The Foundation rents out office space within its complex to the Carle Clinic…

2Cases cited9 opinions

  1. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  2. Fawcus MacHine Co. v. United StatesSupreme Court of the United States · 1931
  3. O'MALLEY v. WoodroughSupreme Court of the United States · 1939
  4. Scripture Press Foundation v. United StatesUnited States Court of Claims · 1961
  5. American Institute for Economic Research v. The United StatesUnited States Court of Claims · 1962

4 more not listed; retrieve them via the Exa API.

3Cited by26 opinions

  1. Amato v. Western Union International, Inc.Court of Appeals for the Second Circuit · 1985
  2. Amato v. Western Union International, Inc.Court of Appeals for the Second Circuit · 1985
  3. Roy E. Dooley, Jr. v. American Airlines, Inc.Court of Appeals for the Seventh Circuit · 1986
  4. Salomon Inc. v. United StatesCourt of Appeals for the Second Circuit · 1992
  5. Geisinger Health Plan v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1993

21 more not listed; retrieve them via the Exa API.

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