Legal Opinion

REDLANDS SURGICAL SERVICES v. Commissioner

United States Tax Court

Decided July 19, 1999No. 11025-97XUnknown

1Opinion of the Court

113 T.C. No. 3

UNITED STATES TAX COURT REDLANDS SURGICAL SERVICES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11025-97X. Filed July 19, 1999. 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.…

2Cases cited44 opinions

  1. Simon v. Eastern Kentucky Welfare Rights OrganizationSupreme Court of the United States · 1976
  2. Bob Jones University v. United StatesSupreme Court of the United States · 1983
  3. Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
  4. B.S.W. Group, Inc. v. CommissionerUnited States Tax Court · 1978
  5. 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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