- 17 - 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 andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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