- 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 and
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011