Redlands Surgical Services v. Commissioner of Internal Revenue

We deny the petition for review on the grounds stated by the tax court in Redlands Surgical Servs. v. C.I.R, 113 T.C. 47, 1999 WL 513862 (1999). Specifically, we adopt the tax court’s holding that appellant Redlands Surgical Services “has ceded effective control over the operations of the partnerships and the surgery center to private parties, conferring impermissible private benefit. [Redlands Surgical Services] is therefore not operated exclusively for exempt purposes within the meaning of § 501(c)(3), I.R.C.1986.” Id at 47. We also affirm the tax court’s conclusion that the benefit…