- 17 - 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 wasPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
Last modified: May 25, 2011