ABA Retirement Funds v. U.S.

Dist. Ct. did not err in finding that plaintiff-not-for-profit corporation that promoted and facilitated operation of tax-qualified retirement plans for ABA members, did not qualify for tax-exempt status for years 2000 through 2002, even though plaintiff argued that it was tax exempt “business league” under section 501(c)(6). Plaintiff failed to show that its activities were directed to improvement of business conditions for legal field generally, where record showed that it merely provided benefits to individual ABA members. Moreover, fact that plaintiff engaged in business ordinarily conducted for profit also precluded it from business league tax exemption.