MIB, Inc. v. Commissioner
United States Tax Court
P is a nonprofit corporation whose membership consists of virtually the entire U.S. life insurance industry. Its primary activity is the operation of a system for the exchange of confidential underwriting information among its members. This helps to detect and deter fraud and misstatements in life insurance applications. Held: P qualifies under sec. 501(c)(6), I.R.C. 1954, as a tax-exempt business league.
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P is a nonprofit corporation whose membership consists of virtually the entire U.S. life insurance industry. Its primary activity is the operation of a system for the exchange of confidential underwriting information among its members. This helps to detect and deter fraud and misstatements in life insurance applications. Held: P qualifies under sec. 501(c)(6), I.R.C. 1954, as a tax-exempt business league. It is not engaged in a business of a kind ordinarily conducted for profit. Furthermore, benefits to particular member companies that use the information exchange are only incidental to…
1Opinion of the Court
Whitaker, Judge:
Respondent determined a deficiency of $1,528,055.42 in petitioner’s Federal income tax for its taxable year ended September 30, 1979, based on his determination that petitioner was not entitled to exemption under sections 501(a)1 and 501(c)(6). He also determined an addition to the tax of $382,013.96 because petitioner’s Federal income tax return (Form 1120) for the 1979 taxable year was not filed until September 9, 1980. Respondent has stipulated that petitioner is not liable for this addition to the tax; thus, the sole issue for decision is whether petitioner is entitled to…
2Cases cited27 opinions
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
- Louisiana Credit Union League v. The United States of AmericaCourt of Appeals for the Fifth Circuit · 1982
- Underwriters' Laboratories, Inc. v. CommissionerCourt of Appeals for the Seventh Circuit · 1943
- Associated Industries v. CommissionerUnited States Tax Court · 1946
- Retailers Credit Ass'n v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1937
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3Cited by7 opinions
- Stearns-Roger Corp., Inc. v. United StatesDistrict Court, D. Colorado · 1984
- Ye Mystic Krewe of Gasparilla v. CommissionerUnited States Tax Court · 1983
- Mib, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1984
- Credit Union Insurance Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1996
- North Carolina Association of Insurance Agents, Inc. v. United StatesCourt of Appeals for the Fourth Circuit · 1984
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