Do contemporary charitable hospitals provide a sufficient community benefit to justify the loss of government revenue caused by their tax exemption? Focusing particularly on federal income tax exemption and on the community benefit derived from the provision of services to persons unable to pay, this Article argues that not all hospitals do. Accordingly, the authors recommend that the Internal Revenue Service issue a Revenue Ruling revising the current standards for federal income tax exemption to encourage charitable hospitals to clearly and explicitly identify and respond to health care needs, including the needs of persons unable to pay, in their local communities. The proposed text of such a ruling is set forth in an appendix to this Article.
James B. Simpson and Sarah D. Strum, How Good a Samaritan? Federal Income Tax Exemption for Charitable Hospitals Reconsidered, 14 SEATTLE U. L. REV. 633 (1991).