The Internal Revenue Service has promoted T.J. Sullivan, one of the agency's healthcare tax experts, to special healthcare assistant to the IRS assistant commissioner for employee benefits and exempt organizations.
The move follows the appointment of James McGovern to the assistant commissioner post last fall (Sept. 6, 1993, p. 22). Mr. McGovern, formerly the associate chief counsel in the EBEO division, replaced John Burke, who retired.
Mr. Sullivan was Mr. McGovern's technical assistant when Mr. McGovern was associate chief counsel.
Both Mr. McGovern and Mr. Sullivan are well known within the healthcare tax field for their questioning of the charitable benefits of transactions involving not-for-profit hospitals. The elevation of agents with healthcare backgrounds to two top posts suggests that the IRS may become tougher on not-for-profit hospitals in the future.
In 1991, the pair played a key role in rewriting an IRS legal opinion that previously approved a specific type of hospital-physician joint venture. The revised opinion said such joint ventures jeopardize a hospital's tax status if the venture is designed to obtain referrals from the physicians involved (Dec. 9, 1991, p. 2).