REDLANDS SURGICAL SERVICES - Page 67




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          a basis for establishing petitioner's exemption.  Cf. Harding               
          Hosp., Inc. v. United States, 505 F.2d 1068 (6th Cir. 1974)                 
          (activities performed by third parties did not provide a basis              
          for organization’s exemption).                                              
               Petitioner asserts that the Surgery Center has no                      
          requirement that patients demonstrate an ability to pay before              
          receiving treatment.  The record does not reflect whether any               
          such policy has been communicated to its patients.  Petitioner              
          suggests that this policy is evidenced by the Surgery Center’s              
          “substantial Medicare” patronage.  The record shows that Medicare           
          accounted for 12 percent of invoices at the Surgery Center in the           
          last half of 1993.  The record does not reflect, however, whether           
          the Surgery Center waives fees in excess of those covered by                
          Medicare and accordingly does not establish that ability to pay             
          is not a factor even for patients covered by Medicare.  Moreover,           
          the Surgery Center’s treatment of Medicare patients cannot on               
          this record be attributed to petitioner’s influence over the                
          Surgery Center’s operations.  According to the affidavit of Mr.             
          James R. Holmes, who was president of petitioner and Redlands               
          Hospital at the time of the affidavit, the Surgery Center “has              
          regularly treated Medicare patients * * * since before 1990.”               











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