- 36 - 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, includingPage: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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