North Carolina Association of Insurance Agents, Inc. v. United States

JAMES DICKSON PHILLIPS, Circuit Judge:

In this income tax refund action, the United States appeals from summary judgment entered in favor of the taxpayer, the North Carolina Association of Insurance Agents, Inc. (NCAIA) on alternative grounds that taxpayer was a tax-exempt business league, or that if not, all of its taxable income was expended for deductible business expenses. We affirm in major part on the second alternative ground, but remand for recomputation of the appropriate amount of refund.

I

This action came before the district court on the parties’ cross-motions for summary judgments…