KANNE, Circuit Judge.
Guide International Corporation is a nonprofit organization whose purpose is to develop data processing products and services, and to provide a forum for the exchange and dissemination of information concerning data processing equipment and systems. In 1971, the Internal Revenue Service determined that Guide was exempt from tax as a nonprofit business league under § 501(c)(6) of the Internal Revenue Code, 26 U.S.C. § 501(c)(6).
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