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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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