American Kennel Club v. Hoey
United States Court of Appeals for the Second Circuit
148 F.2d 920 (1945)
- Written by Daniel Clark, JD
Facts
The American Kennel Club, Inc. (club) (plaintiff) promoted the purity of thoroughbred dogs. The club organized dog and field shows, adopted rules to judge dogs, regulated markets for thoroughbred dogs, maintained a publicly available genealogical registry of thoroughbred dogs, maintained a library—open to the public—with thousands of texts about dogs, and published a monthly magazine that included articles by veterinarians on dog health. The club’s revenues were not used to benefit individual members, and the club operated many of its functions at a financial loss. The club sued to recover remitted taxes, claiming exemption from federal income tax, presumably as a scientific organization. The district court held that the club was not tax-exempt, and the club appealed.
Rule of Law
Issue
Holding and Reasoning (Frank, J.)
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