UNITED STATES TAX COURT
REDLANDS SURGICAL SERVICES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11025-97X.
P is a nonprofit corporation. Its sole activity
is participating as co-general partner with a for-
profit corporation in a partnership that is general
partner of an operating partnership that owns and
operates an ambulatory surgery center. Held: On the
facts involved herein, P has ceded effective control
over the operations of the partnerships and the surgery
center to private parties, conferring impermissible
private benefit. P is therefore not operated
exclusively for exempt purposes within the meaning of
sec. 501(c)(3), I.R.C. 1986.
James L. Malone III and Robert C. Louthian III, for
petitioner.
Joan Ronder Domike and Elizabeth Purcell, for respondent.
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