University Medical Resident Services, P.C. - Page 16

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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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