American College of Physicians v. United States

This case concerns the validity of Treasury Regulations Section 1.513-1 (b) and (d) (4) (iv), examples 6 and 7 promulgated in 1967 pursuant to Sections 511 through 513 of the Internal Revenue Code of 1954,1 insofar as they subject to tax, as unrelated business income, the advertising *25profits of an exempt organization’s journal.2 Plaintiff, the American College of Physicians, seeks a refund of $376,-976.86, plus interest, in Federal income taxes paid for the calendar years 1968 and 1969.

The College, a Delaware corporation organized in 1915 and classified by the Internal Kevenue Service as an…