Geisinger Health Plan v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
1Opinion of the Court
OPINION OF THE COURT
LEWIS, Circuit Judge.
The Commissioner of the Internal Revenue Service (“Commissioner” or “IRS”) appeals from a Tax Court decision granting appellee Geisinger Health Plan (“GHP”) tax-exempt status under 26 U.S.C. § 501(c)(3). This case requires us to decide whether a health maintenance organization (an “HMO”) which serves a predominantly rural population, enrolls some Medicare subscribers, and which intends to subsidize some needy subscribers but, at present, serves only its paying subscribers, qualifies for exemption from federal income taxation under 26 U.S.C. §…
2Cases cited16 opinions
- Simon v. Eastern Kentucky Welfare Rights OrganizationSupreme Court of the United States · 1976
- Bob Jones University v. United StatesSupreme Court of the United States · 1983
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
- Hopkins v. BaconSupreme Court of the United States · 1930
- James E. Threlkeld v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1988
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3Cited by25 opinions
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- Baker v. FAMILY CREDIT COUNSELING COPR.District Court, E.D. Pennsylvania · 2006
- In Re Michael Kaplan Morris Kaplan, Debtors. The Internal Revenue Service v. Michael Kaplan Morris Kaplan, in No. 95-5409. In Re Kaplan Building Systems, Inc., Debtor. Internal Revenue Service v. Kaplan Building Systems, Inc., in No. 96-5180Court of Appeals for the Third Circuit · 1997
- Family Trust of Massachusetts, Inc. v. United StatesDistrict Court, District of Columbia · 2012
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