IHC Care, Inc. - Page 2




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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