National Muffler Dealers Assn., Inc. v. United States

Petitioner, National Muffler Dealers Association, Inc. (Association), as its name indicates, is a trade organization for muffler dealers. The issue in this case is whether the Association, which has confined its membership to dealers franchised by Midas International Corporation (Midas), and its activities to the Midas muffler business, and thus is not “industrywide,” is a “business league” entitled to the exemption from federal income tax provided by § 501 (c) (6) of the Internal Revenue Code of 1954, 26 U. S. C. § 501 (c)(6).1

I

In 1971, during a contest for control of Midas, Midas muffler…