The Hopedale Medical Foundation

“Some nursing home patients hold small amounts of funds on deposit with the hopedale medical foundation (foundation) for incidentals and low value services, such as hair-cuts. The foundation does not record the amounts as assets of the foundation.”

“The hopedale medical foundation (foundation) is a non-for-profit corporation as described in section 501(c)(3) of the internal revenue code (code) and is exempt from federal income taxes on related income pursuant to section 501(a) of the code. The foundation files a form 990 (return of organization exempt from income tax) annually. When this return is filed, it is highly certain that some positions taken would be sustained upon examination by the taxing authorities, while others are subject to uncertainty about the merits of the tax postion taken or the amount of the position that would ultimately be sustained. Examples of tax positions common to hospitals include such matters as the following: the tax-exempt status of the entity, the continued tax exempt status of bonds issued by the obligated group, the nature, the characterization and taxability of joint venture income and various positions relative to potential sources of unrelated business income (ubi). Ubi is reported on form 990-t, as appropriate. The benefit of a tax position is recognized in the consolidated financial statements in the period during which, based on all available evidence, management believes that it is more likely than not that the postion will be sustained upon examination, including the resolution of appeals or litigation processes, if any. Hopedale real estate services, inc. (hres) is a for-profit corporation subject to applicable federal and illinois taxes on income. Hres computes deferred income taxes under the liability method whereby deferred tax assets are recognized for deductible temporary differences and net operating loss and tax credit carryforwards and deferred tax liabilities are recognized for taxable temporary differences. Temporary differences are the differences between the reported amounts of assets and liabilities and their tax basis. Deferred tax assets are reduced by a valuation allowance when, in the opinion of management, it is more likely than not that some or all of the deferred tax assets will not be realized. Deferred tax assets and liabilities are adjusted for the effects of changes in tax laws and rates on the date of enactment. The taxable income of hres and its related current and deferred income taxes are not significant to the consolidated financial statements and are not, therefore, separately presented. Tax positions are not offset or aggregated with other positions. Tax positions that meet the more likely than not recognition threshold are measured as the largest amount of tax benefit that is more than 50% likely to be realized on settlement with the applicable taxing authority. The difference between the benefit of a tax position recorded for financial statement purposes and the amount reflected on a tax return is recorded as a liability for uncertain tax benefits in the accompanying consolidated balance sheets along with any associated interest and penalties that would be payable to the taxing authorities upon examinatioin. As of june 30, 2024 and 2023, there were no uncertain tax benefits related to uncertain tax positions identified and recorded as a liability. Forms 990, 990-t and 1120 filed by the entities are subject to examination by the internal revenue service (irs) up to three years from the extended due date of each return. On january 5, 2016, the fourth district appellate court of illinois ruled that section 15-86 of the illinois property tax code is unconstitutional. This version was appealed to the illinois supreme court, which on march 23, 2017, vacated the fourth district appellate court's ruling, citing a lack of jurisdiction, and remanded the case to circuit court for reconsideration. In septemeber 2018, the illinois supreme court affirmed section 15-86 as constitutional, allowing certain medical centers to use charity care to offset their property tax bills. Management has consulted with legal consel and continues to believe that the foundation meets the requirements under both the illinois st”