REDLANDS SURGICAL SERVICES - Page 3




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          as exempt under section 501(c)(3); and Redlands Health Services,            
          a for-profit corporation.                                                   
              As described in more detail below, and as reflected                    
          schematically in the appendix hereto, in 1990 RHS became co-                
          general partner with a for-profit corporation, Redlands-SCA                 
          Surgery Centers, Inc. (SCA Centers), in a general partnership               
          formed to acquire a 61-percent interest in an existing outpatient           
          surgical center in Redlands, California, two blocks from the                
          Redlands Hospital facility.  This general partnership in turn               
          became sole general partner in the California limited partnership           
          that owns and operates the surgical center.  Under a long-term              
          management contract, SCA Management Co. (SCA Management)--a for-            
          profit affiliate of SCA Centers--manages the day-to-day                     
          operations of the surgical center, in return for a percentage of            
          gross revenues.  Several months after forming the general                   
          partnership, RHS formed petitioner to succeed to its interest in            
          it.                                                                         
               Petitioner has no activity other than its involvement with             
          the partnerships.  The question is whether petitioner is operated           
          exclusively for exempt purposes within the meaning of section               
          501(c)(3).  We hold that it is not.                                         

          Redlands Hospital                                                           
               Since its founding in 1929, Redlands Hospital has been                 
          recognized by respondent as a charitable organization described             





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Last modified: May 25, 2011