Asmark Institute, Inc. v. Comr., No. 11-1553, 2012 U.S. App. LEXIS 13643 (6th Cir. Jul. 3, 2012)

(plaintiff corporation denoted its purpose as agribusiness resource center; predecessor was for-profit consulting business that focused on regulatory compliance; plaintiff claimed that without non-profit status it couldn't partner with trade associations because the couldn't share revenue with for-profit entity; court upheld Tax Court determination that plaintiff not operated exclusively for tax-exempt purposes; plaintiff's operations were commercial rather than charitable and business involved offering fee-based compliance services and plaintiff did not establish that profits would not inure to benefit of private persons or shareholders).