American Medical Ass'n v. United States

MEMORANDUM OPINION AND ORDER

SHADUR, District Judge.

American Medical Association (“AMA”) has sued the United States for a refund of federal income taxes imposed on AMA income earned in the years 1975 through 1978 from the sale of advertising in AMA periodicals. 1 AMA contends the Internal Revenue Service (“IRS”) denied deductions for AMA’s costs of producing and distributing its periodicals that would have been allowed a commercial publisher and are therefore permitted AMA under Internal Revenue Code (“Code”) §§ 511-513, 26 U.S.C. §§ 511-513. 2 Because IRS construed the Code-implementing…