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petitioner conducted its operations on a scale “larger than is
reasonably necessary to accomplish the purposes of the exempt
entities”. Geisinger Health Plans v. Commissioner, 100 T.C. at
406. Based on the record presented, we hold that petitioner does
not satisfy the integral part test.12
In sum, petitioner did not provide the community benefit
required for petitioner to qualify as an organization described
in section 501(c)(3). Further, petitioner’s operations were not
essential to or substantially related to Health Services’ exempt
functions. Consequently, petitioner is not entitled to the
declaratory judgment it seeks.
To reflect the foregoing,
Decision will be entered
for respondent.
12 Under the circumstances, we need not consider whether we
would apply the “boost” test set forth in Geisinger Health Plan
v. Commissioner, 30 F.3d 494, 501 (3d Cir. 1994). In addition,
we need not consider respondent’s alternative contention that
petitioner is not entitled to tax-exempt status pursuant to sec.
501(m).
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