IIT Research Institute v. United States

OPINION

PHILIP R. MILLER, Judge:

This is a suit for refund of taxes for the year 1976, allegedly erroneously collected under the unrelated business taxable income provisions, 26 U.S.C. §§ 511-513 (1982), of the 1954 Internal Revenue Code. The question at issue is whether or not the income from some of the plaintiff’s research contracts for government and business was derived from trade or business unrelated to plaintiff’s exemption as a corporation organized and operated exclusively for scientific purposes.

I

Plaintiff, IIT Research Institute (hereinafter “IITRI”), was organized in 1936 by the…