The American College of Physicians v. The United States

743 F.2d 1570

84-2 USTC P 9796

The AMERICAN COLLEGE OF PHYSICIANS, Appellant,

v.

The UNITED STATES, Appellee.

Appeal No. 84-715.

United States Court of Appeals,

Federal Circuit.

Sept. 17, 1984.

John B. Huffaker, Philadelphia, Pa., argued for appellant. With him on the brief was Eleanor N. Ewing, Washington, D.C.

W.C. Rapp, Washington, D.C., argued for appellee. With him on the brief were Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup and Robert A. Bernstein, Washington, D.C.

Before BALDWIN, SMITH and NIES, Circuit Judges.

EDWARD S. SMITH, Circuit Judge.

1

In this federal income tax case, appellant…