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Petitioners do not claim to qualify independently as educational
organizations, but contend, under the integral part doctrine,
that they are entitled to share in the Consortium members’ exempt
status. See Hospital Bureau of Standards & Supplies, Inc. v.
United States, 141 Ct. Cl. 91, 158 F. Supp. 560 (1958).
The integral part doctrine is not a codified rule, but is a
judicial doctrine recognized in cases, regulations, and revenue
rulings as a basis for derivative exemption under section
501(c)(3). The cases applying this doctrine have held that where
an organization (1) bears a “close and intimate relationship” to
the operation of one or more tax-exempt organizations, and (2)
provides a "necessary and indispensable" service solely to those
tax-exempt organizations, it will take on the exempt status of
those organizations. See, e.g., Hospital Bureau of Standards &
Supplies, Inc. v. United States, supra at 562; Council for
Bibliographic & Info. Technologies v. Commissioner, T.C. Memo.
1992-364.
The rationale behind the integral part doctrine is that an
organization that takes over an essential task which would
otherwise have to be performed by the organizations served should
be exempt because the members would continue to be exempt if they
performed the task themselves. Cf. Hospital Bureau of Standards
& Supplies, Inc. v. United States, supra at 562-563 (concluding
that an organization that took over an essential task was exempt
under integral part doctrine); Nonprofits' Ins. Alliance v.
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