Legal Opinion
Midwest Research Institute v. United States of America, Midwest Research Institute v. United States
Court of Appeals for the Eighth Circuit
Decided September 26, 1984No. 83-1468, 83-1969, 83-1469 and 83-1835PublishedCited by 3 opinions
1Opinion of the Court
FAGG, Circuit Judge.
Midwest Research Institute (MRI) is a non-profit scientific research organization whose tax exemption under 26 U.S.C. § 501(c)(3) is not challenged. The question in this case is whether MRI may recover taxes paid on income it realized from conducting projects for private sponsors on a fee basis. The Internal Revenue Service collected the funds under 26 U.S.C. § 511—513 as tax on income from an unrelated business conducted by a tax-exempt organization.
The district court held that income from the majority of the privately sponsored projects was not taxable as unrelated…
2Cases cited2 opinions
- Iowa Express Distribution, Inc. v. National Labor Relations BoardCourt of Appeals for the Eighth Circuit · 1984
- Midwest Research Institute v. United StatesDistrict Court, W.D. Missouri · 1983
3Cited by3 opinions
- Lawrence Keasler and Keasler Body Company, Inc. v. United StatesCourt of Appeals for the Eighth Circuit · 1985
- 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
- IIT Research Institute v. United StatesUnited States Court of Claims · 1985