U.S. Court of Appeals for the Ninth Circuit, 2001

Redlands Surgical Services v. Commissioner of Internal Revenue

Redlands Surgical Services v. Commissioner of Internal Revenue
U.S. Court of Appeals for the Ninth Circuit · Decided March 15, 2001 · Browning, Brunetti, Hawkins
242 F.3d 904; 2001 Daily Journal DAR 2691; 2001 U.S. App. LEXIS 3937 (Federal Reporter, Third Series)

Redlands Surgical Services v. Commissioner of Internal Revenue

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.

Case-law data current through December 31, 2025. Source: CourtListener bulk data.