Geisinger Health Plan v. Commissioner
United States Tax Court
In Geisinger Health Plan v. Commissioner, 985 F.2d 1210 (3d Cir. 1993), the Court of Appeals remanded this case for a determination of whether P qualifies for exempt status under sec. 501(c)(3), I.R.C., as an integral part of an exempt organization. Held: P has not proven that its activities would not be an unrelated trade or business if conducted by the exempt organization to which it is related. Therefore P is not entitled to exempt status.
1Opinion of the Court
GEISINGER HEALTH PLAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Geisinger Health Plan v. Commissioner
Docket No. 20793-90X
United States Tax Court
100 T.C. 394; 1993 U.S. Tax Ct. LEXIS 26; 100 T.C. No. 26;
May 3, 1993, Filed
Decision will be entered for respondent.
In Geisinger Health Plan v. Commissioner, 985 F.2d 1210 (3d Cir. 1993), the Court of Appeals remanded this case for a determination of whether P qualifies for exempt status under sec. 501(c)(3), I.R.C., as an integral part of an exempt organization. Held: P has not proven that its activities would not be an unrelated…
2Cases cited18 opinions
- Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
- Hopkins v. BaconSupreme Court of the United States · 1930
- O'MALLEY v. WoodroughSupreme Court of the United States · 1939
- B.S.W. Group, Inc. v. CommissionerUnited States Tax Court · 1978
- Stark v. CommissionerUnited States Tax Court · 1986
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