The Grange Insurance Association of California v. Commissioner of Internal Revenue

BROWNING, Circuit Judge.

The Commissioner of Internal Revenue and the Tax Court 1 have concluded that The Grange Insurance Association of California is not exempt from taxation under 26 U.S.C.A. § 501(c) (8), which exempts organizations meeting the following description:

“Fraternal beneficiary societies, orders, or associations — ■

“(A) operating under the lodge system or for the exclusive benefit of the members of a fraternity itself operating under the lodge system, and

“(B) providing for the payment of life, sick, accident, or other benefits to the members of such society, order, or…