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INDEPENDENT INS. AGENTS v. C.I.R.

No. 92-6494.

998 F.2d 898 (1993)

INDEPENDENT INSURANCE AGENTS OF HUNTSVILLE, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

August 20, 1993.

Attorney(s) appearing for the Case

H. Harold Stephens, John R. Wynh, Huntsville, AL, petitioner-appellant.

Gary Allen, Tax Div., Annette M. Wietecha, Teresa T. Milton, Gilbert S. Rothenberg, Dept. of Justice, Washington, DC, for respondent-appellee.

Before BLACK and CARNES, Circuit Judges, and RONEY, Senior Circuit Judge.

BLACK, Circuit Judge:

Independent Insurance Agents of Huntsville, Inc. (IIAH) is a business league that has been exempt from federal taxation under § 501(c)(6) of the Internal Revenue Code1 since 1975. Its membership is open to Madison County, Alabama insurance agencies, licensed brokers, and licensed agents who represent at least two fire and/or casualty companies on a commission basis.

In 1989, the Internal Revenue Service...

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