opinion: AMERICAN KENNEL CLUB, Inc., v. HOEY.
  No. 275.
  Circuit Court of Appeals, Second Circuit.
  April 17, 1945.
  White & Case and Arnold J. Brock, all of New York City (Walter S. Orr, Francis L. Casey, and Arnold J. Brock, all of New York City, of counsel), for plaintiff-appellant.
  John F. X. McGohey, U. S. Atty., of New York City (Laurence H. Axman, of New York City, of counsel), for defendant-appellee.
  Before L. HAND, CHASE, and FRANK, Circuit Judges.
  FRANK, Circuit Judge.
  1. The fact that an organization derives income from services not “scientific” does not preclude exemption. Cf Bohemian Gymnastic Ass’n v. Higgins, 2 Cir., 147 F.2d 774; Oklahoma State Fair and Exposition v. Jones, D.C., 44 F.Supp. 630. But the exemption granted by the statute is only for those organizations whose “purposes” are “exclusively * * * scientific.”
  The word “scientific” has a large variety of meanings. Thus, among savants, there has been much disputation as to whether, with accuracy, history or politics or economics or sociology or “law” is or can be a science. Fortunately,- we are not here required to decide whether in this statute Congress intended to use “scientific” in a restricted or a latitudinarian manner. For, patently, the taxpayer’s prime function is the maintenance, at a high sportsmanlike level, of the sport of dog shows and field trials. Its chief aim is to see that the dog shows are staffed by proper judges and that a fair trial is given to all entrants. However worthy this aim may be, it is not scientific. Doubtless, as plaintiff doggedly asserts, much of the data resulting from taxpayer’s activities can be used scientifically by geneticists, and probably is. But that is not enough. Gambling furnished the data to Pascal and Fermat for working out the mathematical theory of probability, a theory indispensable to modern .physicists. Yet no one would say that, even if today mathematicians and physicists, for their purposes, still studied what went on in gambling houses, such institutions were organized and operated for purposes “exclusively * * * scientific.” The instant case cannot be distinguished- — as was the Bohemian case, supra — from our decision in Jockey Club v. Helvering, 2 Cir., 76 F.2d 597.
  2. Nor can an exemption be justified under § 101(7). Taxpayer is not a business league. The clubs which make up taxpayer s membership are primarily interested in sport, not in business. Thus, though the plaintiff is a league of clubs, it surely is not a league of business clubs.
  3. Our decision of the foregoing questions avoids the necessity of determining whether, under §§ 101(6) or 101(7), any of the profit inured to the benefit of the members.
  Affirmed.
  For recent discussions, see, e.g., Kaufmann, Methodology of The Social Sciences (l944); Neurath, Foundations of The Social Sciences, in International Encyclopedia of Unified Science, Vol. II, No. 1 (1944); Cohen and Nagel, Logic and Scientific Method (1936) Ch. XVII.
instruction: What follows is an opinion from a United States Court of Appeals.
  Intervenors who participated as parties at the courts of appeals should be counted as either appellants or respondents when it can be determined whose position they supported. For example, if there were two plaintiffs who lost in district court, appealed, and were joined by four intervenors who also asked the court of appeals to reverse the district court, the number of appellants should be coded as six.
  When coding the detailed nature of participants, use your personal knowledge about the participants, if you are completely confident of the accuracy of your knowledge, even if the specific information is not in the opinion. For example, if "IBM" is listed as the appellant it could be classified as "clearly national or international in scope" even if the opinion did not indicate the scope of the business. 
  
  Your task concerns the first listed appellant. The nature of this litigant falls into the category "private organization or association", specifically "business, trade, professional, or union (BTPU)". Your task is to determine what subcategory of private association best describes this litigant.
choices: Business or trade association utilities co-ops Professional association - other than law or medicine Legal professional association Medical professional association AFL-CIO union (private) Other private union Private Union - unable to determine whether in AFL-CIO Public employee union- in AFL-CIO (include groups called professional organizations if their role includes bargaining over wages and work conditions) Public Employee Union - not in AFL-CIO Public Employee Union - unable to determine if in AFL-CIO Union pension fund; other union funds (e.g., vacation funds) Other Unclear