West Publishing Co. Employees' Preferred Stock Ass'n v. United States

The plaintiff-taxpayer is an unincorporated association, formed in 1913 as a mutual savings bank for West Publishing Company employees. It lost its tax-exempt status in 1952 with the repeal of § 101(2) of the 1939 Internal Revenue Code (which exempted non-stock mutual savings banks), but nevertheless continued from 1953 to 1965 to file returns as a tax-exempt organization under a good-faith mistake that it still retained the immunity. On audit, the Internal Revenue Service discovered the error and proposed deficiencies for various years totalling $82,139 in income tax and $566,017 of…