IHC Care, Inc. - Page 30




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          its tax-exempt parent somehow enhances or “boosts” its own tax-             
          exempt character to the point that the organization would qualify           
          for tax-exempt status.  Id.  Focusing solely on the latter issue,           
          the Court of Appeals concluded that Geisinger HMO was not                   
          entitled to tax-exempt status because it did not receive the                
          necessary boost from its relationship with exempt Geisinger                 
          entities.  In particular, the Court of Appeals held:                        
                   As our examination of the manner in which * * *                   
               [Geisinger HMO] interacts with other entities in the                   
               System makes clear, its association with those entities                
               does nothing to increase the portion of the community                  
               for which * * * [Geisinger HMO] promotes health–-it                    
               serves no more people as a part of the System than it                  
               would serve otherwise. * * *  [Id. at 502.]                            
          Under the circumstances, the Court of Appeals concluded that it             
          was unnecessary to consider whether Geisinger HMO’s activities              
          would constitute an unrelated trade or business if regularly                
          carried on by a related tax-exempt entity.  Id. at 501.                     
          Analysis                                                                    
               Consistent with the preceding discussion, petitioner’s                 
          qualification for exemption pursuant to section 501(a) as an                
          organization described in section 501(c)(3) initially depends               
          upon whether petitioner satisfies the community benefit test.  In           
          the event that petitioner cannot satisfy the community benefit              
          test, we must consider whether petitioner nevertheless qualifies            
          for exemption as an integral part of a related tax-exempt entity.           








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