Court of Appeals for the Fifth Circuit April 4, 1960, No. 17937 (Birmingham Business College, Inc. v. Commissioner)

JOHN R. BROWN, Circuit Judge.

The principal question is whether Birmingham Business College (BBC) qualifies as a tax exempt entity under § 101(6), 26 U.S.C.A. § 101. The Tax Court held it was not. Related to that are subsidiary issues on the statute of limitations, computation of gross and net income, and the propriety of asserted penalties.