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Background
By way of a brief introduction, petitioner and its
affiliates, IHC Care, Inc. (Care) and IHC Group, Inc. (Group),
operated health maintenance organizations and were part of a
number of companies composing the so-called Intermountain Health
System. Petitioner offered health plans to individuals,
employees of large and small employers, and Medicaid recipients.
At the same time that respondent revoked petitioner’s tax-exempt
status, respondent denied Care’s and Group’s applications for
exemption from Federal income taxation pursuant to section
501(a).1 For completeness, we have provided a detailed
description of the various entities composing the Intermountain
Health System.
I. The Intermountain Health System
A. Intermountain Health Care, Inc.
Between 1882 and 1970, the Church of Jesus Christ of Latter-
Day Saints (LDS Church) constructed or purchased 15 hospitals in
Utah, Idaho, and Wyoming. Prior to 1970, LDS Church hospitals
functioned autonomously with little coordination or centralized
management.
1 Respondent’s determinations to deny IHC Care, Inc.’s and IHC
Group, Inc.’s applications for tax-exempt status are the subjects
of the Court’s opinions in IHC Care, Inc. v. Commissioner, T.C.
Memo. 2001-248, and IHC Group, Inc. v. Commissioner, T.C. Memo.
2001-247.
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Last modified: May 25, 2011