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AMERICAN BAR ENDOWMENT v. UNITED STATES

Appeal Nos. 84-988, 84-1000.

761 F.2d 1573 (1985)

AMERICAN BAR ENDOWMENT, Appellee, v. The UNITED STATES, Appellant. Frederic D. TURNER, et ux., Arthur Sherwood, et ux., et al., Appellants, v. The UNITED STATES, Appellee.

United States Court of Appeals, Federal Circuit.

May 10, 1985.

Attorney(s) appearing for the Case

Robert S. Pomerance, Tax Div., Dept. of Justice, of Washington, D.C., for appellant U.S. With him on the brief were B. John Williams, Jr., Acting Asst. Atty. Gen., Gary R. Allen and Robert A. Bernstein.

Francis M. Gregory, Jr., Sutherland, Asbill & Brennan, of Washington, D.C., for appellee. With him on the brief were Randolph W. Thrower, Sheila J. Carpenter and Barbara J. Groves.

Before FRIEDMAN, DAVIS, and BENNETT, Circuit Judges.

DAVIS, Circuit Judge.

These are consolidated appeals from the decision of the United States Claims Court, Kozinski, C.J., in American Bar Endowment v. United States, 4 Cl.Ct. 404 (1984). In No. 84-988, the Government appeals from that portion of the ruling which held that appellee American Bar Endowment (the Endowment) earns no unrelated business taxable income from a fund-raising program in which the Endowment obtains a group insurance policy for its...

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