Monterey Public Parking Corporation v. United States

KELLEHER, District Judge:

Appellant seeks reversal of the District Court’s judgment, after trial, granting appellee a refund of income taxes for three prior years upon a finding that the appellee is exempt from federal income taxes under Int.Rev.Code of 1954, § 501 (c)(3) and (4) 1 as either a corporation organized and operated exclusively for charitable purposes, or as a civic league or an organization “not organized for profit but operated, exclusively for the promotion of social welfare.”

In substance, appellant contends that to the extent the trial court failed to examine separately the…