REDLANDS SURGICAL SERVICES - Page 83

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          partners.  Moreover, as previously discussed, petitioner                    
          impermissibly serves private interests.  Petitioner’s activity is           
          not so substantially and closely related to the exempt purposes             
          of its affiliates that these private interests may be                       
          disregarded.  See Geisinger Health Plan v. Commissioner, 100 T.C.           
          at 406, 407.  Accordingly, petitioner is not entitled to                    
          exemption under the integral part doctrine.                                 
               Remaining contentions not addressed herein we deem                     
          irrelevant, without merit, or unnecessary to reach.                         
               To reflect the foregoing,                                              

                                        Decision will be entered                      
                                    for respondent.                                   

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