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UNITED STATES v. AMERICAN BAR ENDOWMENT

No. 85-599.

477 U.S. 105 (1986)

UNITED STATES v. AMERICAN BAR ENDOWMENT ET AL.

Supreme Court of United States.

Decided June 23, 1986

Attorney(s) appearing for the Case

Albert G. Lauber, Jr., argued the cause for the United States. With him on the briefs were Solicitor General Fried, Acting Assistant Attorney General Olsen, Gary R. Allen, and Robert S. Pomerance.

Francis M. Gregory, Jr., argued the cause for respondents. With him on the brief were Randolph W. Thrower, Mac Asbill, Jr., and Sheila J. Carpenter.*

JUSTICE MARSHALL delivered the opinion of the Court.

The first issue in this case is whether income that a taxexempt charitable organization derives from offering group insurance to its members constitutes "unrelated business income" subject to tax under §§ 511 through 513 of the Internal Revenue Code (Code), 26 U. S. C. §§ 511-513. The second issue is whether the organization's members may claim a charitable deduction for the portion of their...

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