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PITTSBURGH PRESS CLUB v. UNITED STATES

No. 79-1492.

615 F.2d 600 (1980)

PITTSBURGH PRESS CLUB v. UNITED STATES of America, Appellant.

United States Court of Appeals, Third Circuit.

Decided February 20, 1980.

Attorney(s) appearing for the Case

Robert J. Cindrich, U. S. Atty., Thomas A. Daley, Asst. U. S. Atty., Pittsburgh, Pa., M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Leonard J. Henzke, Jr., Robert T. Duffy (Argued), Attys., Tax Div., Dept. of Justice, Washington, D. C., for appellant.

Leonard M. Mendelson (Argued), T. Lawrence Palmer, Hollinshead & Mendelson, Pittsburgh, Pa., for appellee.

Before GIBBONS, HIGGINBOTHAM and SLOVITER,

OPINION OF THE COURT

A. LEON HIGGINBOTHAM, Jr., Circuit Judge.

This case involves a suit for the refund of federal income taxes and the Government's counterclaim for uncollected interest. These claims result from the revocation of the Pittsburgh Press Club's tax exemption as a nonprofit social club under Section 501(c)(7) of the Internal Revenue Code of 1954 (the Code) because the Club's trade with nonmembers constituted an impermissible business for profit...

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