IHC Health Plans, Inc. - Page 2

                                        - 2 -                                         
          exemption from Federal income taxation pursuant to section                  
          501(a).  The revocation was retroactive to January 1, 1987.                 
          Unless otherwise indicated, section references are to sections of           
          the Internal Revenue Code, as amended, and Rule references are to           
          the Tax Court Rules of Practice and Procedure.                              
          Respondent revoked petitioner’s tax-exempt status under                     
          section 501(c)(3) on the grounds that:  (1) Petitioner was not              
          operated exclusively for a tax-exempt purpose; and (2)                      
          petitioner’s activities were tantamount to providing commercial-            
          type insurance within the meaning of section 501(m)(1).                     
          Petitioner filed a timely petition for declaratory judgment                 
          pursuant to section 7428(a) challenging respondent’s                        
          determination letter.  At the time the petition was filed,                  
          petitioner’s principal place of business was in Salt Lake City,             
               The administrative record was submitted to the Court                   
          pursuant to Rule 217(b)(1).  The facts contained in the                     
          administrative record are assumed to be true for purposes of this           
          proceeding.  See Rule 217(b)(1).  The case was submitted to the             
          Court by joint motion of the parties pursuant to Rule 122.  The             
          parties also filed a stipulation of facts with attached exhibits.           
          The parties agree that petitioner has satisfied all                         
          jurisdictional requirements.  See sec. 7428(b); Rule 210(c).                

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011