Contemporary Mission, Inc. Plaintiff-appellant, v. the United States, Defendant-appellee, 852 F.2d 1293 (Fed. Cir. 1988)

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US Court of Appeals for the Federal Circuit - 852 F.2d 1293 (Fed. Cir. 1988)

June 21, 1988

Before EDWARD S. SMITH, NIES and MICHEL, Circuit Judges.


Contemporary Mission, Inc. (Mission), appeals the judgment of the United States Claims Court in Contemporary Mission, Inc. v. United States, No. 557-79T (Cl.Ct. filed June 17, 1987) (Harkins, S.J.). The Claims Court held that Mission failed to prove it was operated exclusively for tax-exempt purposes, and that there was no inurement to the benefit of its members. That court concluded that Mission did not qualify as a tax-exempt organization under section 501(c) (3) of the Internal Revenue Code of 1954, as amended. On the basis of the opinion of the trial judge, the Claims Court's decision is affirmed.