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review we may draw our own ultimate conclusions and inferences
from the facts. See Am. Campaign Acad. v. Commissioner, supra at
1063-1064; Houston Lawyer Referral Serv., Inc. v. Commissioner,
supra at 573-575.
Section 501(c)(3) specifies various qualifying exempt
purposes, including "charitable" purposes. The term "charitable"
is not defined in section 501(c)(3) but is used in its generally
accepted legal sense. See Nationalist Movement v. Commissioner,
102 T.C. 558 (1994), affd. per curiam 37 F.3d 216 (5th Cir.
1994); sec. 1.501(c)(3)-1(d)(2), Income Tax Regs.
Charitable Purpose
The Supreme Court has stated that “Charitable exemptions are
justified on the basis that the exempt entity confers a public
benefit-–a benefit which the society or the community may not
itself choose or be able to provide, or which supplements and
advances the work of public institutions already supported by tax
revenues.” Bob Jones Univ. v. United States, supra at 591.
Although neither the furnishing of medical care nor the operation
of an HMO is listed as a qualifying exempt activity under section
501(c)(3), it is now well settled that the promotion of health
for the benefit of the community is a charitable purpose. See
Redlands Surgical Servs. v. Commissioner, supra at 73; Sound
Health Association v. Commissioner, 71 T.C. 158, 177-181 (1978).
As discussed in detail below, a health-care provider seeking tax-
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