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U. S. v. AMERICAN COLLEGE OF PHYSICIANS

No. 84-1737.

475 U.S. 834 (1986)

106 S.Ct. 1591

89 L.Ed.2d 841

UNITED STATES v. AMERICAN COLLEGE OF PHYSICIANS

Supreme Court of United States.

Decided April 22, 1986

Attorney(s) appearing for the Case

Albert G. Lauber, Jr., argued the cause for the United States. With him on the briefs were Solicitor General Fried, Assistant Attorney General Archer, Robert A. Bernstein, and Robert S. Pomerance.

John B. Huffaker argued the cause for respondent. With him on the brief were Eleanor N. Ewing and Gerald P. Norton.*

JUSTICE MARSHALL delivered the opinion of the Court.

A tax-exempt organization must pay tax on income that it earns by carrying on a business not "substantially related" to the purposes for which the organization has received its exemption from federal taxation. The question before-this Court is whether respondent, a tax-exempt organization, must pay tax on the profits it earns by selling commercial advertising space in its...

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