Legal Opinion

American College of Physicians v. United States

United States Court of Claims

Decided October 21, 1983No. 415-82TPublishedCited by 10 opinions

1Opinion of the Court

OPINION

KOZINSKI, Chief Judge.

Plaintiff American College of Physicians, a tax-exempt organization, challenges the Commissioner’s determination that income earned from advertising in the College’s journal, Annals of Internal Medicine, is subject to the Unrelated Business Income Tax (UBIT). 26 U.S.C. §§ 511-513 (1976).

*533Facts1

The College is an organization exempt from taxation under section 501(c)(3). Its tax-exempt purposes are to uphold and maintain high standards in medical education, medical practice and medical research; to encourage research, especially in clinical medicine; and to foster…

2Cases cited6 opinions

  1. Malat v. RiddellSupreme Court of the United States · 1966
  2. Sweatt v. PainterSupreme Court of the United States · 1950
  3. McLaurin v. Oklahoma State Regents for Higher EducationSupreme Court of the United States · 1950
  4. O'MALLEY v. WoodroughSupreme Court of the United States · 1939
  5. Disabled American Veterans v. United StatesUnited States Court of Claims · 1981

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3Cited by10 opinions

  1. United States v. American College of PhysiciansSupreme Court of the United States · 1986
  2. Shiloh Youth Revival Centers v. CommissionerUnited States Tax Court · 1987
  3. The American College of Physicians v. The United StatesCourt of Appeals for the Federal Circuit · 1984
  4. American Bar Endowment v. United StatesUnited States Court of Claims · 1984
  5. Stahl v. United StatesDistrict Court, E.D. Washington · 2009

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