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National Muffler Deals Assn., Inc. v. United States, 440 U.S. 472 (1979)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
National Muffler Deals Assn., Inc. v. United States, 440 U.S. 472 (1979)
National Muffler Deals Assn., Inc. v. United States No. 77-1172 Argued November 27, 1978 Decided March 20, 1979 440 U.S. 472
CERTIORARI TO THE UNITED STATES COURT OF APPEALS
FOR THE SECOND CIRCUIT
Syllabus
Petitioner is a trade organization for muffler dealers, but it has confined its membership to dealers franchised by Midas International Corporation and its activities to Midas’ muffler business. In a suit seeking a federal income tax refund, petitioner claimed the "business league" exemption provided by § 501(c)(6) of the Internal Revenue Code of 1954. Treas.Reg. § 1.5’1(c)(6)-1 states that a business league is "an organization of the same general class as a chamber of commerce or board of trade," and that a tax exempt business league’s activities "should be directed to the improvement of business conditions of one or more lines of business." The District Court held that Midas muffler franchisees do not constitute a "line of business," and that petitioner was not a "business league" within the meaning of § 501(c)(6), and thus was not entitled to the claimed refund. The Court of Appeals affirmed, applying the maxim noscitur a sociis and holding that petitioner’s purpose was too narrow to satisfy the "line of business" test of the Regulation.
Held: Petitioner is not entitled to the tax exemption as a "business league" within the meaning of § 501(c)(6). Pp. 476-489.
565 F.2d 845, affirmed.
BLACKMUN, J., delivered the opinion of the Court, in which BURGER, C.J., and BRENNAN, WHITE, MARSHALL, and POWELL, JJ., joined. STEWART, J., filed a dissenting opinion, in which REHNQUIST and STEVENS, JJ., joined, post, p. 489.
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Chicago: U.S. Supreme Court, "Syllabus," National Muffler Deals Assn., Inc. v. United States, 440 U.S. 472 (1979) in 440 U.S. 472 440 U.S. 473. Original Sources, accessed November 24, 2024, http://originalsources.com/Document.aspx?DocID=EX7H6M2LFHLTFV4.
MLA: U.S. Supreme Court. "Syllabus." National Muffler Deals Assn., Inc. v. United States, 440 U.S. 472 (1979), in 440 U.S. 472, page 440 U.S. 473. Original Sources. 24 Nov. 2024. http://originalsources.com/Document.aspx?DocID=EX7H6M2LFHLTFV4.
Harvard: U.S. Supreme Court, 'Syllabus' in National Muffler Deals Assn., Inc. v. United States, 440 U.S. 472 (1979). cited in 1979, 440 U.S. 472, pp.440 U.S. 473. Original Sources, retrieved 24 November 2024, from http://originalsources.com/Document.aspx?DocID=EX7H6M2LFHLTFV4.
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