Contracting Plumbers Cooperative Restoration Corporation v. United States

J. JOSEPH SMITH, Circuit Judge;

This is an appeal by the government from a determination by the District Court for the Eastern District of New York, Mark A. Costantino, Judge, that taxpayer is exempt as both a “civic organization,” 26 U.S.C. § 501(c)(4), and a “business league,” 26 U.S.C. § 501(c)(6). While we believe that taxpayer’s activities are totally commendable, we nevertheless find that Congress has imposed certain limitations on those two exemptions and that taxpayer simply does not qualify. We therefore reverse.

I

Taxpayer’s sole purpose is .to insure the efficient repair of “cuts”…