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
OPINION
Cohen, Judge:
This case is now before the Court pursuant to remand from the Court of Appeals for the Third Circuit in its opinion reversing our holding that petitioner’s health maintenance organization (HMO) is an organization described in section 501(c)(3). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at the time the petition was filed, and all Rule references are to the Tax Court Rules of Practice and Procedure.
The Court of Appeals held that petitioner Geisinger Health Plan (ghp), standing alone, is not entitled to tax-exempt status…
2Cases cited17 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
12 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Redlands Surgical Servs. v. CommissionerUnited States Tax Court · 1999
- Airlie Foundation v. Internal Revenue ServiceDistrict Court, District of Columbia · 2003
- Geisinger Health Plan v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Third Circuit · 1994
- IHC GROUP v. COMMISSIONERUnited States Tax Court · 2001
- Geisinger Health Plan v. Comm. IRSCourt of Appeals for the Third Circuit · 1994
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