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Section 501(c)(3) of the Internal Revenue Code of
1954, as amended (or the corresponding provision
of any future United States Internal Revenue Law
or (ii) by a corporation, contributions to which
are deductible under Section 170(c)(2) of the
Internal Revenue Code of 1954, as amended (or the
corresponding provision of any future United
States Internal Revenue Law).
Petitioner's bylaws limit membership to one member. The
sole member is RHS, which has the right to elect, remove, and
fill vacancies in petitioner's Board of Directors. Petitioner's
bylaws provide that the directors must be among those persons
serving as members of the Enterprise Committee of petitioner's
parent corporation RHS.
Petitioner's sole source of financial support is its share
of the revenues from the Operating Partnership. Petitioner has
no paid or salaried employees. The president of Redlands
Hospital serves concurrently as petitioner’s president.
The Surgery Center's Operations
The Surgery Center operates on a nondiscriminatory basis
both as to doctors and patients. There are no restrictions as to
whether a surgical patient can be operated on at the Surgery
Center, other than a review as to the appropriateness of
conducting the surgical procedure in an outpatient setting and
the overall medical condition of the patient. There is
practically a 100-percent overlap between surgeons who operate at
Redlands Hospital and at the Surgery Center.
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