Legal Opinion

Midwest Research Institute v. United States

District Court, W.D. Missouri

Decided February 2, 1983No. 78-0875-CV-W-6PublishedCited by 7 opinions

1Opinion of the Court

MEMORANDUM AND ORDER

SACHS, District Judge.

This case, filed in 1978 after some fifteen years of administrative proceedings, is a suit for a tax refund, to recover $461,958.02 in taxes assessed for the years 1962-1970 and paid under protest in 1977. Plaintiff Midwest Research Institute (MRI) is a private not-for-profit corporation that is organized and operated for “scientific .. . purposes” and thus enjoys a tax exemption pursuant to 26 U.S.C. § 501(c)(3). MRI’s tax-exempt status is not challenged in this action. Defendant contends, however, that a portion of plaintiff’s income earned during…

2Cases cited17 opinions

  1. United States v. CorrellSupreme Court of the United States · 1967
  2. Scripps-Howard Radio, Inc. v. Federal Communications CommissionSupreme Court of the United States · 1942
  3. Helvering v. WinmillSupreme Court of the United States · 1938
  4. Commissioner v. Portland Cement Co. of UtahSupreme Court of the United States · 1981
  5. C. F. Mueller Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1951

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3Cited by7 opinions

  1. Stanley Spencer v. National Labor Relations BoardCourt of Appeals for the D.C. Circuit · 1983
  2. Lawrence Keasler and Keasler Body Company, Inc. v. United StatesCourt of Appeals for the Eighth Circuit · 1985
  3. United States v. Cannons Engineering Corp.District Court, D. Massachusetts · 1989
  4. Noel A. Brinker v. Lewis O. Guiffrida, Director of the Federal Emergency Management Agency United States of AmericaCourt of Appeals for the Third Circuit · 1986
  5. Midwest Research Institute v. United States of America, Midwest Research Institute v. United StatesCourt of Appeals for the Eighth Circuit · 1984

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