- 48 - ‘est’ for 2 years after terminating their relationship with ‘est’ organizations. In est of Hawaii v. Commissioner, supra at 1080, this Court agreed with respondent that the nonprofit was “part of a franchise system which is operated for private benefit and * * * its affiliation with this system taints it with a substantial commercial purpose.” We found that the “ultimate beneficiaries” of the nonprofit’s activities were the for-profit corporations, and that the nonprofit “was simply the instrument to subsidize the for-profit corporations and not vice versa”. Id. at 1082. This Court held that the nonprofit was not operated exclusively for exempt purposes. See also Harding Hosp., Inc. v. United States, 505 F.2d 1068 (6th Cir. 1974) (impermissible private benefit resulted from a nonprofit hospital's contract with a physician group, giving them a virtual monopoly over care of the hospital's patients and the income stream they represented, and providing the physician group with fees for supervising the hospital's medical staff); Sonora Community Hosp. v. Commissioner, 46 T.C. 519 (1966) (impermissible private benefit resulted from an arrangement whereby a for-profit laboratory was permitted to occupy space in the nonprofit hospital rent-free, and paid the hospital’s founding doctors a share of the laboratory’s gross revenues in consideration of patient referrals and administrative services), affd. 397 F.2d 814 (9th Cir. 1968).Page: Previous 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 Next
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