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PROFESSIONAL INS. AGENTS OF MICHIGAN v. C.I.R.

No. 82-1591.

726 F.2d 1097 (1984)

PROFESSIONAL INSURANCE AGENTS OF MICHIGAN, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided January 26, 1984.

Rehearing and Rehearing Denied March 26, 1984.

Attorney(s) appearing for the Case

Joseph Falcone, argued, Lieberman & Falcone, P.C., Southfield, Mich., for petitioner-appellant.

Kenneth W. Gideon, Chief Counsel, John H. Menzel, I.R.S., Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Chief, Appellate Section, Robert A. Bernstein, David I. Pincus, argued, Tax. Div., Dept. of Justice, Washington, D.C., for respondent-appellee.

Before ENGEL and KENNEDY, Circuit Judges, and MORTON, Chief District Judge.

Rehearing and Rehearing En Banc Denied March 26, 1984.

MORTON, Chief District Judge.

Professional Insurance Agents of Michigan (PIA), is a trade association exempt from federal income taxation as a "business league" under Section 501(c)(6) of the Internal Revenue Code of 1954. PIA was formed in 1937, incorporated as a non-profit corporation under the laws of Michigan in 1956, and received an Internal Revenue Service ruling that it qualified as an exempt organization...

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