Redlands Surgical Services v. Commissioner of Internal Revenue
REDLANDS SURGICAL SERVICES, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee
Opinion
PER CURIAM:
We deny the petition for review on the grounds stated by the tax court in Redlands Surgical Servs. v. C.I.R, 113 T.C. 47 , 1999 WL 513862 (1999). Specifically, we adopt the tax court’s holding that appellant Redlands Surgical Services “has ceded effective control over the operations of the partnerships and the surgery center to private parties, conferring impermissible private benefit. [Redlands Surgical Services] is therefore not operated exclusively for exempt purposes within the meaning of § 501(c)(3), I.R.C.1986.” Id at 47. We also affirm the tax court’s conclusion that the benefit conferred on private parties by the surgery center’s operations prevents *905 Redlands Surgical Services from attaining tax exempt status under the integral part doctrine.
Petition for Review DENIED.
How later courts describe this case
Explanatory parentheticals written by citing courts — 1 in all; the most informative distinct ones are shown.
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(holding that a non-profit organization is no longer entitled to tax-exempt status when it “has ceded effective control . . . to private parties”)
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