Florida Hospital Trust Fund v. Commissioner
Court of Appeals for the Eleventh Circuit
1Opinion of the Court
HILL, Senior Circuit Judge:
This tax appeal presents a narrow issue of first impression in this Circuit and others: do three trust funds, organized to provide a vehicle for small to mid-size member hospitals reciprocally to “self’ insure each other on a group basis against hospital professional liability and workers’ compensation claims, qualify as tax-exempt “cooperative hospital service organizations” for purposes of § 501(e) of the Internal Revenue Code of 1986, 26 U.S.C. § 501(e) (Code). Finding no clear error, we affirm the decision of the Tax Court.
I. BACKGROUND
The salient facts are not…
2Cases cited7 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
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- American Association of Christian Schools Voluntary Employees Beneficiary Ass'n Welfare Plan Trust v. United StatesCourt of Appeals for the Eleventh Circuit · 1988
- Senior Citizens Stores, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1979
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