American Hospital Ass'n v. United States

MEMORANDUM

LEIGHTON, Senior District Judge.

Plaintiff has brought a claim for refund action with respect to income taxes imposed on income received from periodicals it published during the years 1973 and 1974. It alleges: (1) that its periodical income is tax-exempt; 1 (2) that the IRS misconstrued the applicable Treasury Regulation, Treas. Reg. § 1.512(a)-l(f)(4)(i) (1975); (3) that the IRS improperly classified certain publication costs as “readership costs” rather than “direct advertising costs”; (4) that the IRS improperly interpreted the fractional allocation formula of Treas. Reg. §…