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HARDING HOSPITAL, INC. v. UNITED STATES

No. 73-1661.

505 F.2d 1068 (1974)

HARDING HOSPITAL, INC., Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Sixth Circuit.

November 13, 1974.

Attorney(s) appearing for the Case

Herbert R. Brown, Vorys, Sater, Seymour & Pease, Richard R. Stedman, Byron E. Ford, Columbus, Ohio, for plaintiff-appellant.

William W. Milligan, U. S. Atty., Columbus, Ohio, Scott P. Crampton, Asst. Atty. Gen., Meyer Rothwacks, Thomas R. Jones, Donald R. Anderson, Elmer Kelsey, Murray S. Horwitz, Tax Div., Dept. of Justice, Washington, D. C., for defendant-appellee.

Before PHILLIPS, Chief Judge, and EDWARDS and PECK, Circuit Judges.

PHILLIPS, Chief Judge.

The sole issue presented in this appeal is whether Harding Hospital, Inc. (the Hospital) qualified under § 501(c) (3) of the Internal Revenue Code of 1954 as an organization exempt from federal income taxes during the years 1966, 1967 and 1968. The District Court determined, inter alia, that the Hospital was not operated exclusively for charitable purposes and denied the exemption. We affirm.

I.

Reference is made...

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