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entities. In particular, the Court of Appeals held:
As our examination of the manner in which * * *
[Geisinger HMO] interacts with other entities in the
System makes clear, its association with those entities
does nothing to increase the portion of the community
for which * * * [Geisinger HMO] promotes health–-it
serves no more people as a part of the System than it
would serve otherwise. * * * [Id. at 502.]
Under the circumstances, the Court of Appeals concluded that it
was unnecessary to consider whether Geisinger HMO’s activities
would constitute an unrelated trade or business if regularly
carried on by a related tax-exempt entity. Id. at 501.
Analysis
Consistent with the preceding discussion, petitioner’s
qualification for exemption pursuant to section 501(a) as an
organization described in section 501(c)(3) initially depends
upon whether petitioner satisfies the community benefit test. In
the event that petitioner cannot satisfy the community benefit
test, we must consider whether petitioner nevertheless qualifies
for exemption as an integral part of a related tax-exempt entity.
Even assuming that petitioner qualifies as an organization
described in section 501(c)(3), respondent contends that
petitioner is not entitled to tax-exempt status under section
501(m) which provides that an organization described sec.
501(c)(3) shall not be entitled to tax-exempt status if a
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