IHC Group, Inc. - Page 36




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          remaining 79 percent of such physician services directly with               
          independent physician medical groups.  In other words,                      
          petitioner’s enrollees received nearly 80 percent of their                  
          physician services from physicians with no direct link to one of            
          petitioner’s tax-exempt affiliates.                                         
               Petitioner contends that its contracts with independent                
          medical groups are not relevant to the question of whether                  
          petitioner qualifies for tax-exempt status as an integral part of           
          its tax-exempt IHC affiliates because all such independent                  
          physicians were required to maintain privileges at Health                   
          Services hospitals.  We disagree with the basic premise                     
          underlying petitioner’s argument.                                           
          Health Services was composed of the hospital division, which                
          operated a large number of hospitals and clinics, and the                   
          physician division, which employed 245 primary care physicians              
          and 215 specialist physicians who generally practiced in Health             
          Services’ clinics and other community-based settings.  Health               
          Services’ status as an organization described in section                    
          501(c)(3) is undoubtedly attributable to its participation in               
          Medicare, Medicaid, and other governmental programs, and its                
          willingness to provide charity services.  Considering that                  
          petitioner does not provide free or low cost health services, and           
          given the termination of its Senior Care plan for Medicare                  
          patients, we fail to see how petitioner’s operations, including             






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Last modified: May 25, 2011