Pittsburgh Press Club v. United States

OPINION OF THE COURT

A. LEON HIGGINBOTHAM, Jr., Circuit Judge.

This case involves a suit for the refund of federal income taxes and the Government’s counterclaim for uncollected interest. These claims result from the revocation of the Pittsburgh Press Club’s tax exemption as a nonprofit social club under Section 501(c)(7) of the Internal Revenue Code of 1954 (the Code) because the Club’s trade with nonmembers constituted an impermissible business for profit. The Government appeals for the third time from a judgment entered in the Club’s favor. We hold that the district court’s findings of fact…