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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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