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Center, the SCA affiliates have been enabled to operate it as a
profit-making business, with significantly reduced competitive
pressures from Redlands Hospital, and largely unfettered by
charitable objectives that might conflict with purely commercial
objectives. Cf. est of Hawaii v. Commissioner, 71 T.C. 1067,
1080 (1979); Housing Pioneers, Inc. v. Commissioner, T.C. Memo.
1993-120, affd. 49 F.3d 1395 (9th Cir. 1995). The net result to
the SCA affiliates is a nonincidental "advantage; profit; fruit;
privilege; gain; [or] interest" that constitutes a prohibited
private benefit. See American Campaign Academy v. Commissioner,
92 T.C. 1053, 1065 (1989).
D. Conclusion
Based on all the facts and circumstances, we hold that
petitioner has not established that it operates exclusively for
exempt purposes within the meaning of section 501(c)(3). In
reaching this holding, we do not view any one factor as crucial,
but we have considered these factors in their totality: The lack
of any express or implied obligation of the for-profit interests
involved in petitioner's sole activity to put charitable
objectives ahead of noncharitable objectives; petitioner's lack
of voting control over the General Partnership; petitioner's lack
of other formal or informal control sufficient to ensure
furtherance of charitable purposes; the long-term contract giving
SCA Management control over day-to-day operations as well as a
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