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FINDINGS OF FACT
Some of the facts have been stipulated for trial pursuant to
Rule 91 and are incorporated herein by reference. We find as
facts the parties' stipulations of fact.
Petitioner is a labor organization exempt from taxation
pursuant to section 501(c)(5). Petitioner’s principal office, at
the time of the filing of the petition in the instant case, was
388 Hillside Avenue, Needham, Massachusetts.
The purpose of petitioner is: (1) To represent and act as
bargaining agent in matters of policy, wages, hours, and other
conditions of employment, and to engage in other concerted
activities for the purpose of collective bargaining or other
mutual aid or protection, of and for the members of the Uniformed
Branch of the Division of State Police, Department of Public
Safety, of the Commonwealth of Massachusetts, and (2) to promote
and develop a friendly and fraternal spirit among all of the
members of the Uniformed Branch of the Division of State Police.
Approximately 1,100 to 1,300 State troopers were eligible to
join petitioner during each of the taxable years in issue.
Nearly all those who were eligible to be members were members.
The Constabulary was the official publication of petitioner and
was intended for both internal and external use. The
Constabulary was characterized as petitioner’s "yearbook" or "ad-
book".
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Last modified: May 25, 2011