- 47 - with Health Services, while petitioner contracted for the remaining 80 percent of such physician services directly with independent physicians. In other words, petitioner’s enrollees received nearly 80 percent of their physician services from physicians with no direct link to one of petitioner’s tax-exempt affiliates. Petitioner contends that its contracts with independent physicians are not relevant to the question of whether it qualifies for tax-exempt status as an integral part of its tax- exempt IHC affiliates because all such independent physicians were required to maintain privileges at Health Services’ hospitals. We disagree with the basic premise underlying petitioner’s argument. Health Services comprised the hospital division, which operated a large number of hospitals and clinics, and the physician division, which employed approximately 400 primary care and specialist physicians who generally practiced in Health Services’ clinics and other community-based settings. Considering that petitioner does not provide free or low cost health services, we fail to see how petitioner’s operations, including its heavy reliance on independent physicians, would be essential to or substantially related to Health Services’ exempt functions. To the contrary, petitioner’s method of arranging for its enrollees to receive physician services suggests thatPage: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Next
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