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(2) Subsidiary organizations having a common
parent organization. An exempt organization is not
related to another exempt organization merely
because they both engage in the same type of exempt
activities.
Since Squire, only a relatively small number of cases have
applied the integral part doctrine. These cases are fact-
specific. See Geisinger Health Plan v. Commissioner, 30 F.3d
494, 501 (3d Cir. 1994), affg. 100 T.C. 394 (1993), and cases
cited therein. As applied in a number of these cases, the
integral part doctrine requires the organization in question to
provide “necessary and indispensable” services solely to an
exempt organization to which it bears some legal or significant
operational relationship. See, e.g., Hospital Bureau of
Standards & Supplies, Inc. v. United States, 141 Ct. Cl. 91, 158
F. Supp. 560, 562 (1958) (recognizing exemption of an
organization that provided “necessary and indispensable” product
testing and purchasing of hospital supplies for its exempt member
hospital); University Med. Resident Servs., P.C. v. Commissioner,
T.C. Memo. 1996-251 (membership organizations that conducted
clinical training programs for member universities were not
exempt); Council for Bibliographic & Info. Techs. v.
Commissioner, T.C. Memo. 1992-364 (recognizing exemption of an
organization that conducted “necessary and indispensable”
activities for exempt member libraries). As applied in these
cases, the integral part doctrine operates to recognize a
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