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Even if we were to assume, arguendo, that the patient
populations of the Surgery Center and Redlands Hospital overlap
substantially, this circumstance would not suffice to confer
exemption on petitioner under the integral part doctrine. In all
the precedents cited above in which courts have applied the
integral part doctrine to recognize a derivative exemption, the
organization has been under the supervision or control of the
exempt affiliate (or a group of exempt affiliates with common
exempt purposes) or otherwise expressly limited in its purposes
to advancing the interests of the affiliated exempt entity or
entities, and serving no private interests.24 For instance, in
Squire v. Student Book Corp., 191 F.2d 1018, 1019 (9th Cir.
1951), all actions of the bookstore's board of trustees were
submitted to the president of the college for approval, and the
college comptroller acted as ex officio treasurer of the
bookstore. The bookstore paid no rebates and no part of its
earnings inured to private benefit. It seems clear that such
considerations are central to the court's holding in Squire that
24 In Geisinger Health Plan v. Commissioner, 100 T.C. 394,
402 (1993), affd. 30 F.3d 494 (3d Cir. 1994), we stated that the
parties had agreed that “an organization is entitled to exemption
as an integral part of a tax-exempt affiliate if its activities
are carried out under the supervision or control of an exempt
organization and could be carried out by the exempt organization
without constituting an unrelated trade or business” (emphasis
added). In Geisinger, we made a factual finding that the
affiliated exempt foundation controlled the HMO. See id. at 396.
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