University Medical Resident Services, P.C. - Page 17

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          United States, 32 Fed. Cl. 277, 288 (1994) (concluding that an                
          organization that took over a nonessential task was not exempt                
          under the integral part doctrine).  In cases granting exemption               
          based on the integral part doctrine, the organization seeking                 
          exemption invariably contributed to the attainment of its                     
          members’ exempt purpose.  Nonprofits' Ins. Alliance v. United                 
          States, supra; cf. Northern Cal. Cent. Servs., Inc. v. United                 
          States, 219 Ct. Cl. 60, 591 F.2d 620 (1979) (involving an                     
          independent corporation that provided higher quality laundry                  
          services for member hospitals at lower cost in furtherance of                 
          their exempt purpose); Estate of Thayer v. Commissioner, 24 T.C.              
          384 (1955) (involving an independently funded trust that                      
          published a newsletter and operated a scholarship program in                  
          furtherance of a university’s exempt purpose).                                
               In the present case, petitioners’ function is merely                     
          incidental to the exempt purpose of the organizations they                    
          serve.  Indeed, the Consolidation Contract states that "the                   
          employment of the * * * [residents] is ancillary to the primary               
          purpose of graduate medical and dental education".  (Emphasis                 
          added.)  A comparison of the facts in Hospital Bureau and Council             
          for Bibliographic & Info. Technologies with those in the present              
          case further establishes this point.  In Hospital Bureau and                  
          Council for Bibliographic & Info. Technologies, the organizations             
          seeking exemption took over functions previously performed by the             
          organizations they served in order to achieve cost reductions and             

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