- 18 - better achieve the organizations’ exempt purpose. Hospital Bureau of Standards & Supplies v. United States, supra (involving a corporation that took over the purchasing of hospital supplies in order to achieve volume discounts for its members); Council for Bibliographic & Info. Technologies v. Commissioner, supra (involving a corporation that took over operation and maintenance of a computerized library research system enabling member libraries to better perform their exempt functions). In the present case, petitioners are superfluous corporate shells that make no cognizable contribution to the education of residents. Despite petitioners' incorporations, all funds continue to be provided by the Schools and hospitals, and all program-related decisions continue to be made through the Consortium. The Schools and the hospitals continue to supervise and train the residents and pay their salaries. In addition, the Consortium continues to make the policy decisions, just as it has since 1983. The only change since the incorporation of petitioners is that the money used to pay residents is funneled through petitioners before it reaches the residents. As the Consolidation Contract states, the Consortium has “overall management and program control” with respect to the education of residents. Petitioners are merely "corporations controlled by * * * [the Consortium]." In substance, petitioners appear to be appendages rather than integral parts.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