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IHC HEALTH PLANS, INC. v. C.I.R.

Nos. 01-9013 to 01-9015.

325 F.3d 1188 (2003)

IHC HEALTH PLANS, INC., on its own behalf and as successor in interest to IHC Group, Inc., and IHC Care, Inc., Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

April 9, 2003.

Attorney(s) appearing for the Case

Douglas M. Mancino (Robert C. Louthian, III, Robert E. Kohn, and David L. Hirsch, with him on the briefs), McDermott, Will & Emery, Los Angeles, California, appearing for the Appellant.

Teresa E. McLaughlin, Attorney, Tax Division, Department of Justice (Eileen J. O'Connor, Assistant Attorney General, and Gary R. Allen, Attorney, Tax Division, Department of Justice, with her on the brief), Washington, DC, appearing for the Appellee.

Before TACHA, Chief Circuit Judge, HOLLOWAY, and EBEL, Circuit Judges.

TACHA, Chief Circuit Judge.

I. Background1

IHC Health Plans, Inc. ("Health Plans"), on its own behalf and as successor in interest to IHC Care, Inc. ("Care") and IHC Group, Inc. ("Group") (collectively "petitioners"),2 appeals the Tax Court's decision denying petitioners' request for tax exemption under 26 U.S.C. § 501(c)(3). We have jurisdiction...

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