Legal Opinion

Florida Hosp. Trust Fund v. Commissioner

United States Tax Court

Decided August 4, 1994No. Docket Nos. 2966-93X, 2967-93X, 2968-93XPublished

P1 and P2 are organizations established under Fla. Stat. Ann. sec. 627.357 (West 1994) to serve as Medical Malpractice Risk Management Trust Funds. P3 is an organization established under Fla. Stat. Ann. sec. 440.57 (West 1991) to serve as a Group Self-Insurer Fund.

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P1 and P2 are organizations established under Fla. Stat. Ann. sec. 627.357 (West 1994) to serve as Medical Malpractice Risk Management Trust Funds. P3 is an organization established under Fla. Stat. Ann. sec. 440.57 (West 1991) to serve as a Group Self-Insurer Fund. Ps' members, who are either government-run hospitals as described in sec. 501(e)(1)(B)(iii), I.R.C., or hospitals qualifying as organizations described in sec. 501(c)(3), I.R.C., utilize Ps to pool their resources on a group basis for the purpose of insuring against hospital professional liability, excess hospital professional…

1Opinion of the Court

Florida Hospital Trust Fund, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Florida Hosp. Trust Fund v. Commissioner

Docket Nos. 2966-93X, 2967-93X, 2968-93X

United States Tax Court

103 T.C. 140; 1994 U.S. Tax Ct. LEXIS 53; 103 T.C. No. 10;

August 4, 1994, Filed

Decisions will be entered for respondent.

P1 and P2 are organizations established under Fla. Stat. Ann. sec. 627.357 (West 1994) to serve as Medical Malpractice Risk Management Trust Funds. P3 is an organization established under Fla. Stat. Ann. sec. 440.57 (West 1991) to serve as a Group Self-Insurer Fund. Ps'…

2Cases cited25 opinions

  1. United States v. American Trucking AssociationsSupreme Court of the United States · 1940
  2. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  3. Burk-Waggoner Oil Assn. v. HopkinsSupreme Court of the United States · 1925
  4. Helvering v. Le GierseSupreme Court of the United States · 1941
  5. HCSC-Laundry v. United StatesSupreme Court of the United States · 1981

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