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GEISINGER HEALTH PLAN v. C.I.R.

No. 93-7699.

30 F.3d 494 (1994)

GEISINGER HEALTH PLAN, Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Appellee.

United States Court of Appeals, Third Circuit.

Decided July 27, 1994.

Attorney(s) appearing for the Case

Lawrence J. Goode, Frederick J. Gerhart (argued), Melissa B. Rasman, Philadelphia, PA, for appellant.

Gary R. Allen, Teresa E. McLaughlin (argued), U.S. Dept. of Justice, Tax Div., Washington, DC, for appellee.

Before: BECKER and LEWIS, Circuit Judges, and IRENAS, District Judge.

OPINION OF THE COURT

LEWIS, Circuit Judge.

In Geisinger Health Plan v. Commissioner of Internal Revenue, 985 F.2d 1210 (3d Cir.1993) ("Geisinger I"), we held that the Geisinger Health Plan ("GHP"), a health maintenance organization ("HMO"), was not entitled to exemption from federal income taxation as a charitable organization under 26 U.S.C. § 501(c)(3). We remanded the case for determination of whether...

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