IHC Health Plans, Inc. - Page 28

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          were permitted to become members while paying reduced premiums.             
          Aside from the free health screenings mentioned above, petitioner           
          did not provide or arrange to provide free health care services.            
          Section 501(c)(3)                                                           
               To qualify as an organization described in section 501(c)(3)           
          that is exempt from Federal income taxation pursuant to section             
          501(a), an organization generally must demonstrate:  (1) It is              
          organized and operated exclusively for certain specified exempt             
          purposes; (2) no part of its net earnings inures to the benefit             
          of a private shareholder or individual; (3) no part of its                  
          activities constitutes intervention or participation in any                 
          political campaign on behalf of any candidate for public office;            
          and (4) no substantial part of its activities consists of                   
          political or lobbying activities.  See Fla. Hosp. Trust Fund v.             
          Commissioner, 103 T.C. 140, 145 (1994), affd. 71 F.3d 808 (11th             
          Cir. 1996); Am. Campaign Acad. v. Commissioner, 92 T.C. 1053,               
          1062 (1989).                                                                
               Qualification as an organization described in section                  
          501(c)(3) not only provides an exemption from Federal income                
          taxes, but also generally permits the organization to solicit and           
          accept donations which normally are deductible by the donor                 
          against his or her Federal taxes.  See sec. 170(c); Bob Jones               
          Univ. v. United States, 461 U.S. 574, 577-578 (1983).  With a few           

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