IHC Health Plans, Inc. - Page 33

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          served the private interests of its members as opposed to the               
          interests of the community.                                                 
               In Sound Health Association v. Commissioner, supra at 182-             
          183, we utilized the same factors deemed significant by the                 
          Commissioner in granting tax-exempt status to one of two                    
          hospitals under review in Rev. Rul. 69-545, 1969-2 C.B. 117, and            
          referred to the factors cited favorably in that ruling as the               
          community benefit test.  In Sound Health Association, we                    
          concluded that the subject organization shared several                      
          characteristics with the hospital deemed exempt in Rev. Rul. 69-            
          545, supra.  In particular, like the hospital in the revenue                
          ruling, Sound Health Association operated a medical clinic and              
          employed physicians and nurses to provide medical services, and             
          opened its emergency room to all persons requiring emergency care           
          whether they were members or not and regardless of whether they             
          were financially able to pay.  Sound Health Association also                
          established a research program to study health care delivery                
          systems, conducted a health education program open to the general           
          public, and was governed by a board of directors the majority of            
          whom were elected by Sound Health Association members from the              
          community at large.  Sound Health Association v. Commissioner,              
          supra at 184.                                                               
               We found that Sound Health Association provided community              
          benefits beyond those offered by the hospital deemed exempt in              

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