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health plans. Petitioner did not subsidize premiums for persons
who were unable to afford its premiums, and petitioner did not
retain existing enrollees who failed to pay their premiums.
Petitioner did not conduct any medical, health care, or
scientific research.
III. Petitioner’s Application for Exemption
In 1986, petitioner filed with respondent an application for
recognition as an organization described in section 501(c)(3)
that is exempt from taxation pursuant to section 501(a).
Petitioner’s application stated that it intended to operate for
the charitable purpose of promoting health for the benefit of the
community.
On October 29, 1998, respondent issued a final adverse
determination letter to petitioner denying its application for
tax-exempt status pursuant to section 501(c)(4). The record does
not reflect the date that petitioner filed its application for
exemption under section 501(c)(4) or whether petitioner filed a
petition for declaratory judgment with the Court challenging
respondent’s determination under section 501(c)(4).
On June 16, 1999, respondent issued a final adverse
determination letter to petitioner denying its application for
tax-exempt status pursuant to section 501(c)(3). Respondent
determined that petitioner did not qualify as an organization
described in section 501(c)(3) on the ground that petitioner was
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