Sansing (2000) (hereafter, the paper) examines an interesting setting in which similar services are offered by both taxable and tax-exempt entities. While tax exemption provides an obvious benefit in terms of after-tax return on investment in the activity, differences in production costs and entity objectives create conditions under which both entities might efficiently provide services in response to market demand. The paper explores conditions under which formation of a joint venture between these entities may be mutually beneficial, and examines the impact of alternative regulatory regimes on joint-venture formation and control, as well as social welfare. This type of setting is idea for research, because the separate entities exist and operate as a result of diverse preferences and market forces, yet that diversity creates potential opportunities for mutually beneficial collaboration. The paper is rigorous in its modeling and analysis, and its results are clearly presented. This discussion focuses on three primary issues affecting the form of the model, its external validity, motivations, and implications. With respect to the model itself, the objective function specified for the nonprofit organization is examined. In terms of external validity, the definition of ‘‘control’’ put forth by Revenue Ruling 98-15 is explored, and that definition is related to the structure of the model. Finally, the potential for broadening the appeal of the paper beyond the healthcare setting is considered.