Laborers' International Union of North America - Page 2




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          which resulted in the following deficiencies in its Federal                 
          income tax and additions thereto:                                           
                                        Addition to tax                               
                    Year     Deficiency   sec. 6651(a)                                
                    1987      $348,590      $87,148                                   
                    1988       195,821       48,955                                   
                    1989       153,612       38,403                                   
                    1990       193,902       48,476                                   
                    1993       361,042       90,261                                   
                    1994       359,321       89,830                                   
                    1995       427,903      106,976                                   
                    1996       433,685      108,421                                   
               Following respondent’s concession that petitioner is not               
          liable for the additions to tax, and our prior holding that                 
          respondent failed to determine timely deficiencies for 1987,                
          1988, and 1989 we are left to decide whether petitioner received            
          UBTI in 1990 and in 1993 through 1996, inclusive.                           
                                  FINDINGS OF FACT2                                   
               Petitioner is a labor union whose principal office was in              
          Washington, D.C., when the petition was filed.  During the                  
          subject years, petitioner was a tax-exempt labor organization               
          under section 501(c)(5).  Petitioner is an accrual method                   
          taxpayer that uses the calendar year for purposes of its                    
          consolidated Federal income tax return.                                     
               Petitioner is affiliated with other unions.  The National              
          Postal Mail Handlers Union (Mail Handlers) is affiliated with               
          petitioner under an “Agreement of Affiliation”.  Mail Handlers is           



               2 Some of the facts have been stipulated and are so found.             





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