EDUCO, INC. v. ALEXANDER

No. 76-1852.

557 F.2d 617 (1977)

EDUCO, INC., Plaintiff-Appellant, v. Donald C. ALEXANDER, Commissioner of Internal Revenue, et al., Defendants-Appellees.

United States Court of Appeals, Seventh Circuit.

Decided July 15, 1977.


Attorney(s) appearing for the Case

Paul A. Teschner, Chicago, Ill., for plaintiff-appellant.

Scott P. Crampton, Asst. Atty. Gen., Philip I. Brennan, Atty., Tax Div., Dept. of Justice, Washington, D. C., Samuel K. Skinner, U. S. Atty., Chicago, Ill., for defendants-appellees.

Before CUMMINGS, PELL, and BAUER, Circuit Judges.


CUMMINGS, Circuit Judge.

Plaintiff Educo, Inc., is a corporation which has engaged in the business of designing, implementing and administrating educational benefit plans for corporate employees for over a decade. On September 2, 1975, defendant Commissioner of Internal Revenue issued Technical Information Release (TIR) 1406, subsequently republished as Revenue Ruling 75-448 (1975-2 C.B. 55), which significantly changed the tax status of the transactions involved...

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