Florida Hosp. Trust Fund v. Commissioner
United States Tax Court
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
OPINION
NlMS, Judge:
Respondent determined that Florida Hospital Trust Fund, Florida Hospital Excess Trust Fund B, and Florida Hospital Workers’ Compensation Self-Insurance Fund (petitioners) do not qualify as organizations described in section 501(c)(3), and thus are not exempt from Federal income taxation under section 501(a). (Unless otherwise indicated, all section references are to sections of the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure.)
Petitioners invoked the jurisdiction of this Court, pursuant to section 7428(a), for a…
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