IHC Care, Inc. - Page 24




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          established a research program to study health care delivery                
          systems, conducted a health education program open to the general           
          public, and was governed by a board of directors the majority of            
          whom were elected by Sound Health Association members from the              
          community at large.  Sound Health Association v. Commissioner,              
          supra at 184.                                                               
               We found that Sound Heath Association provided community               
          benefits beyond those offered by the hospital deemed exempt in              
          Rev. Rul. 69-545, supra.  Specifically, Sound Health Association            
          adopted a plan to accept contributions for the purpose of                   
          subsidizing membership for those who could not otherwise afford             
          to pay the full amount of monthly dues.  Further, Sound Health              
          Association’s practice of offering membership to the public at              
          large demonstrated that the class of persons eligible to benefit            
          from the organization’s activities was practically unlimited.               
          Sound Health Association v. Commissioner, supra at 184-185.                 
               We rejected the Commissioner’s argument that Sound Health              
          Association provided an unwarranted private benefit to its                  
          members.  We reasoned that, like the hospital deemed exempt in              
          Rev. Rul. 69-545, supra, which (except in emergency cases)                  
          limited its treatment to paying patients, Sound Health                      
          Association was permitted to restrict its services to paying                
          members.  Sound Health Association v. Commissioner, supra at 186-           
          187.                                                                        






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Last modified: May 25, 2011