Significant developments in the law of tax-exempt healthcare organizations occurred during the early 1990s. The span of developments includes a seminal Seventh Circuit case, Living Faith v. Commissioner, as well as an Internal Revenue Service determination letter recognizing the charitable tax status of integrated delivery systems, showing the recent activism of the IRS in the healthcare arena. In addition, the federal and state courts have struggled to define and apply concepts of community benefit and charity to modern healthcare organizations.

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