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B. IHC Health Services, Inc.
During 1983, IHC organized a nonprofit affiliate, IHC Health
Services, Inc. (Health Services). IHC transferred substantially
all of its assets, including its hospital properties, and
substantially all of its liabilities, to Health Services.
Respondent recognized Health Services as an organization
described in section 501(c)(3) that is exempt from taxation
pursuant to section 501(a).
Health Services conducted its activities through two
divisions, the hospital division and the physician division,
which are described in detail below.
1. The Hospital Division
Health Services’ hospital division comprised 23 hospitals
(including 2,644 licensed beds) located in Utah and Idaho. All
Health Services hospitals, with the exception of Primary
Children’s Medical Center (Primary Children’s) and McKay-Dee
Institute for Behavioral Medicine (McKay-Dee Institute), were
general acute care hospitals that provided inpatient and
outpatient services and varying levels of emergency, ancillary,
and specialized services. The scope of services varied with the
size of the hospital and the needs of the particular community.
All Health Services hospitals participated in the Medicare and
Medicaid programs for inpatient and outpatient hospital services,
and for a number of free-standing ambulatory care services such
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