- 44 - secs. 368, 372 (4th ed. 1989). As applied to determinations of qualification for tax exemption, the definition of the term “charitable” has not been static. See Eastern Ky. Welfare Rights Org. v. Simon, supra at 1287-1290; Sound Health Association v. Commissioner, supra. Suffice it to say that, in recognition of changes in the health-care industry, the standard no longer requires that “the care of indigent patients be the primary concern of the charitable hospital, as distinguished from the care of paying patients”. Sound Health Association v. Commissioner, supra at 180. Rather, the standard reflects "a policy of insuring that adequate health care services are actually delivered to those in the community who need them.” Id. at 180-181. Under this standard, health-care providers must meet a flexible community benefit test based upon a variety of indicia, one of which may be whether the organization provides free care to indigents. Cf. id. at 184-185 (subsidized dues program was an indicium of charitable purposes). To benefit the community, a charity must serve a sufficiently large and indefinite class; as a corollary to this rule, private interests must not benefit to any substantial degree. See id. at 181. C. Proscription Against Benefiting Private Interests An organization does not operate exclusively for exempt purposes if it operates for the benefit of private interests suchPage: Previous 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 Next
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