HCSC-Laundry v. United States
450 U.S. 1 (1981)

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U.S. Supreme Court

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

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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