REDLANDS SURGICAL SERVICES - Page 79




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          derivative exemption of an organization which serves only another           
          exempt organization and performs essential services that the                
          client organization otherwise would have performed for itself to            
          accomplish its own exempt purposes.  See B.S.W. Group, Inc. v.              
          Commissioner, 70 T.C. 352, 360 (1978); University Med. Resident             
          Servs., P.C. v. Commissioner, supra, and cases cited therein.               
               Consistent with this rationale, professional group practices           
          serving exempt entities have been granted tax exemption under the           
          integral part doctrine.  See University of Mass. Med. Sch. Group            
          Practice v. Commissioner, 74 T.C. 1299 (1980); B.H.W. Anesthesia            
          Found., Inc. v. Commissioner, 72 T.C. 681 (1979); University of             
          Md. Physicians, P.A. v. Commissioner, T.C. Memo. 1981-23.  These            
          cases involved anesthesiology services or faculty medical                   
          activities that were provided solely to the served hospital or              
          medical school and that were essential to the operation of the              
          hospital or medical school.  See Geisinger Health Plan v.                   
          Commissioner, 100 T.C. 394 (1993).                                          
               In Geisinger Health Plan v. Commissioner, supra, this Court            
          denied a claim for tax exemption asserted by an HMO under the               
          integral part theory.  We reasoned that the group-practice line             
          of cases was not controlling because, unlike the exempt                     
          organizations in those cases, the HMO had a population of                   
          subscribers that did not overlap substantially with the patients            
          of the related exempt entities.  In considering whether the HMO’S           






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