- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011