- 3 - 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.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