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indicated, section references are to sections of the Internal
Revenue Code, as amended, and Rule references are to the Tax
Court Rules of Practice and Procedure. Petitioner filed a timely
petition for declaratory judgment pursuant to section 7428(a)
challenging respondent’s determination letter. At the time the
petition was filed, petitioner’s principal place of business was
in Salt Lake City, Utah.
The administrative record was submitted to the Court
pursuant to Rule 217(b)(1). The facts contained in the
administrative record are assumed to be true for purposes of this
proceeding. See Rule 217(b)(1). The case was submitted to the
Court by joint motion of the parties pursuant to Rule 122. The
parties agree that petitioner has satisfied all jurisdictional
requirements. See sec. 7428(b); Rule 210(c).
Background
By way of a brief introduction, petitioner, along with its
sister corporation IHC Group, Inc. (Group), and their common
parent, IHC Health Plans, Inc. (Health Plans), operated health
maintenance organizations and were part of a number of companies
comprising the so-called Intermountain Health System. Petitioner
offered health plans to the employees of employers with more than
100 employees. At the same time that respondent denied
petitioner’s application for tax-exempt status, respondent denied
Group’s application for tax-exempt status and revoked Health
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Last modified: May 25, 2011