AMERICAN MEDICAL ASS'N v. U.S.

Nos. 88-3012, 88-3086.

887 F.2d 760 (1989)

AMERICAN MEDICAL ASSOCIATION, Plaintiff-Appellee, Cross-Appellant, v. UNITED STATES of America, Defendant-Appellant, Cross-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided October 12, 1989.


Attorney(s) appearing for the Case

George A. Platz, Michael L. Schultz, Frank V. Battle, Jr., Sidley & Austin, Chicago, Ill., for American Medical Ass'n.

Gary R. Allen, William S. Rose, Jr., Asst. Atty. Gen., Dept. of Justice, Tax Div., Appellate Section, Washington, D.C., Eileen M. Marutzky, Asst. U.S. Atty., Chicago, Ill., Robert S. Pomerance, David M. Moore, Thomas R. Jones, Dept. of Justice, Tax Div., Robert A. Saltzstein, Joseph J. Saunders, Stephen M. Feldman, Washington, D.C., for U.S.

Before CUDAHY, MANION and KANNE, Circuit Judges.


CUDAHY, Circuit Judge.

This case involves the allocation of income and expenses between a charitable organization's tax-exempt activities and its taxable business endeavors for purposes of computing the charity's "unrelated business income tax" under 26 U.S.C. sections 511 to 513. The American Medical Association (the "AMA"), a tax-exempt charitable organization, filed suit in the Northern District of Illinois seeking a refund for the tax years 1975 through 1978....

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