Sound Health Ass'n v. Commissioner
United States Tax Court
Petitioner is a Health Maintenance Organization (HMO) organized as a nonprofit corporation under the laws of the State of Washington. Petitioner is a membership organization. It provides health care services to its members on a prepaid basis, and to nonmembers on a fee-for-service basis.
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Petitioner is a Health Maintenance Organization (HMO) organized as a nonprofit corporation under the laws of the State of Washington. Petitioner is a membership organization. It provides health care services to its members on a prepaid basis, and to nonmembers on a fee-for-service basis. Emergency cases are handled without regard to whether the patient is a member or not and petitioner provides free care, or care at reduced rates, to a limited number of indigent patients per year. Respondent ruled that petitioner was qualified as an organization described in sec. 501(c)(4), but denied…
1Opinion of the Court
OPINION
Sterrett, Judge:
This is an action for declaratory relief brought by petitioner Sound Health Association against respondent Commissioner of Internal Revenue Service under the terms of new section 7428, I.R.C. 1954. Respondent has determined that petitioner qualifies as an organization described in section 501(c)(4), but fails to qualify as an organization described in section 501(c)(3). The only issue before the Court is whether or not petitioner qualifies as an organization described in section 501(c)(3).
The administrative record herein (sometimes referred to as the record), which…
2Cases cited11 opinions
- Simon v. Eastern Kentucky Welfare Rights OrganizationSupreme Court of the United States · 1976
- Bartels v. BirminghamSupreme Court of the United States · 1947
- Green v. ConnallyDistrict Court, District of Columbia · 1971
- B.S.W. Group, Inc. v. CommissionerUnited States Tax Court · 1978
- Eastern Kentucky Welfare Rights Organization v. William E. Simon, Secretary of the TreasuryCourt of Appeals for the D.C. Circuit · 1974
6 more not listed; retrieve them via the Exa API.
3Cited by36 opinions
- Federation Pharmacy Services, Inc. v. CommissionerUnited States Tax Court · 1979
- First Libertarian Church v. CommissionerUnited States Tax Court · 1980
- Geisinger Health Plan v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1993
- Harvard Community Health Plan, Inc. v. Board of Assessors of CambridgeMassachusetts Supreme Judicial Court · 1981
- IHC Health Plans, Inc. v. CommissionerCourt of Appeals for the Tenth Circuit · 2003
31 more not listed; retrieve them via the Exa API.