IHC Health Plans, Inc. - Page 10




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          to comply with regulatory requirements and to simplify operations           
          from an organizational and managerial standpoint.                           
          Petitioner was licensed to operate an HMO in Utah and was                   
          permitted to offer a variety of individual and group health plans           
          in the communities that it served.  In June 1985, respondent                
          recognized petitioner as an organization described in section               
          501(c)(3) that is exempt from taxation pursuant to section                  
          501(a).                                                                     
               1.  IHC Care, Inc.                                                     
               In January 1985, petitioner organized Care as a nonprofit              
          affiliate for the purpose of establishing a federally qualified             










          3(...continued)                                                             
               The number of Trustees of the Corporation shall be not                 
               less than four (4) or more than twenty-three (23)                      
               persons, as determined from time to time by the Member.                
               The initial number of trustees shall be eighteen (18).                 
               A plurality of Board members shall represent the buyer-                
               employer community and an approximately equal number of                
               physicians and hospital representatives shall be                       
               appointed.  Buyer-employer members shall be broadly                    
               representative of the major geographic areas and                       
               business interests (such as manufacturing, retailing,                  
               transportation, finance, utilities, education, etc.) to                
               be served by the Corporation’s health care delivery                    
               plans, and physician members shall also reflect such                   
               geographic areas as well as major medical specialties                  
               and modes of practice. * * *                                           





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