Guide International Corporation v. United States
United States Court of Appeals for the Seventh Circuit
948 F.2d 360 (1991)
- Written by Sean Carroll, JD
Facts
Guide International Corporation (Guide) (plaintiff) was a nonprofit organization formed for the purpose of promoting best practices of data-processing systems. Guide’s primary activity was producing three conferences per year to that end. Guide’s members included corporations and other organizations representing a wide variety of fields. However, Guide’s membership was limited to organizations that used equipment manufactured by IBM Corporation. IBM comprised 70 to 75 percent of the mainframe-computer industry. In 1971, the Internal Revenue Service (IRS) (defendant) determined that Guide was exempt from taxation as a business league or trade association pursuant to Internal Revenue Code § 501(c)(6). After a 1983 ruling from the IRS, however, Guide’s exempt status was less clear. Guide filed income tax returns for 1984, 1985, and 1986 and then filed for a tax refund. When the IRS did not respond to the refund request, Guide filed suit in federal court. The district court granted the IRS summary judgment, ruling that Guide did not qualify as a business league. Guide appealed.
Rule of Law
Issue
Holding and Reasoning (Kanne, J.)
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