Redlands Surgical Services v. Commissioner of Internal Revenue

Ninth Circuit

Redlands Surgical Services v. Commissioner of Internal Revenue

242 F.3d 904, 2001 Daily Journal DAR 2691, 2001 U.S. App. LEXIS 3937

CourtCourt of Appeals for the Ninth Circuit

DecidedMarch 15, 2001

Docket99-71253

StatusPublished

Cited by16 cases

This text of 242 F.3d 904 (Redlands Surgical Services v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Redlands Surgical Services v. Commissioner of Internal Revenue, 242 F.3d 904, 2001 Daily Journal DAR 2691, 2001 U.S. App. LEXIS 3937 (9th Cir. 2001).

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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.

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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.

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242 F.3d 904, 2001 Daily Journal DAR 2691, 2001 U.S. App. LEXIS 3937, Counsel Stack Legal Research, https://law.counselstack.com/opinion/redlands-surgical-services-v-commissioner-of-internal-revenue-ca9-2001.

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