IHC Care, Inc. - Page 3




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          Plans’ tax-exempt status.1  For completeness, we have provided a            
          detailed description of the various entities comprising the                 
          Intermountain Health System.                                                
          I.  The Intermountain Health System                                         
          A.  Intermountain Health Care, Inc.                                         
               Between 1882 and 1970, the Church of Jesus Christ of Latter-           
          Day Saints (LDS Church) constructed or purchased 15 hospitals in            
          the States of Utah, Idaho, and Wyoming.  During 1970, LDS Church            
          organized Intermountain Health Care, Inc. (IHC), as a nonprofit             
          corporation under the laws of the State of Utah.  LDS Church                
          organized IHC for the purpose of assuming ownership and control             
          of LDS Church hospitals.  During 1975, LDS Church relinquished              
          control of IHC.  Respondent recognized IHC as an organization               
          described in section 501(c)(3) that is exempt from taxation                 
          pursuant to section 501(a).                                                 
               Over a period of several years, IHC organized a group of               
          affiliate corporations for the purpose of forming a comprehensive           
          health care network with operations in Utah and surrounding                 
          states.                                                                     
          B.  IHC Health Services, Inc.                                               
               During 1983, IHC organized a nonprofit affiliate, IHC Health           


          1   Respondent’s determinations to deny IHC Group, Inc.’s                   
          application for tax-exempt status and to revoke IHC Health Plans,           
          Inc.’s tax-exempt status are the subjects of the Court’s opinions           
          in IHC Group, Inc. v. Commissioner, T.C. Memo. 2001-247 and IHC             
          Health Plans, Inc. v. Commissioner, T.C. Memo. 2001-246.                    




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