TANG, Circuit Judge:
Plaintiff/Appellee, the Engineers Club of San Francisco, filed suit in federal district court seeking reclassification as a business league under IRC § 501(c)(6), 26 U.S.C. § 501(c)(6). A business league classification would entitle Engineers Club to income tax refunds on its unrelated business income for the years 1978-81. The district court held that Engineers Club met the requirements of § 501(c)(6) and qualified as a business...
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