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Hcsc-Laundry v. United States, 450 U.S. 1 (1981)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Hcsc-Laundry v. United States, 450 U.S. 1 (1981)
HCSC-Laundry v. United States No. 80-338 Decided February 23, 1981 450 U.S. 1
ON PETITION FOR WRIT OF CERTIORARI TO THE UNITED STATES
COURT OF APPEALS FOR THE THIRD CIRCUIT
Syllabus
Held: A cooperative hospital service organization cannot qualify for exemption from federal income taxation as a charitable organization under § 501(c)(3) of the Internal Revenue Code of 1954, but instead may qualify only if it performs one of the services listed in § 501(e)(1)(A). This conclusion is supported both by the principle of statutory construction that a specific statute, here subsection (e), controls over a general provision such as subsection (c)(3), particularly when the two are interrelated and closely positioned, and by the legislative history. Since laundry service was deliberately omitted from the list of services in subsection (e), petitioner, a nonprofit corporation organized to provide laundry services for exempt hospitals and an exempt ambulance service, is not entitled to tax-exempt status.
Certiorari granted; 624 F.2d 428, affirmed.
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Chicago: U.S. Supreme Court, "Syllabus," Hcsc-Laundry v. United States, 450 U.S. 1 (1981) in 450 U.S. 1 Original Sources, accessed November 24, 2024, http://originalsources.com/Document.aspx?DocID=9W58L451YBGX7PZ.
MLA: U.S. Supreme Court. "Syllabus." Hcsc-Laundry v. United States, 450 U.S. 1 (1981), in 450 U.S. 1, Original Sources. 24 Nov. 2024. http://originalsources.com/Document.aspx?DocID=9W58L451YBGX7PZ.
Harvard: U.S. Supreme Court, 'Syllabus' in Hcsc-Laundry v. United States, 450 U.S. 1 (1981). cited in 1981, 450 U.S. 1. Original Sources, retrieved 24 November 2024, from http://originalsources.com/Document.aspx?DocID=9W58L451YBGX7PZ.
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