Hospital Services Ass'n v. United States

OPINION AND ORDER

WHEELER, Judge.

This tax case is before the Court on Defendant’s February 28, 2007 Motion for Summary Judgment, and Plaintiffs April 30, 2007 Cross-Motion for Partial Summary Judgment. Plaintiff, Hospital Services Association of Northeastern Pennsylvania (“HSA”), filed this action to recover federal income taxes alleged to have been erroneously overpaid for the years 1991 through 1997.1 HSA is a Blue Cross/Blue Shield (“BC/BS”) organization that was exempt from federal income tax until the Tax Reform Act of 1986 (the “Tax Reform Act”) took effect on January 1, 1987. Pub.L. No.…