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sponsor, or provide the insurance program operated by the Mail
Handlers’ health plan.3
Petitioner raises funds to cover its cost of operation by
levy of a “per capita tax” on its own members and on affiliated
unions. Per capita taxes are the traditional way that national
and international unions fund their activities to accomplish
their exempt purposes. During the subject years, petitioner
levied a per capita tax on Mail Handlers. The tax was calculated
with reference to the number of regular and associate members of
Mail Handlers. These per capita taxes were set at different
rates for the associate and regular members. During the years in
issue, petitioner engaged in the following activities: Serving as
the voice of its regular members in the labor movement at large
and operating a substantial legislative department that lobbies
Congress and Federal agencies for legislation and regulations
that will benefit its regular members and affiliated bodies.
Petitioner also engaged in coordinating the legal strategy and
efforts for its affiliates and providing direct legal services
where appropriate, maintaining professionally staffed departments
for research, education, international affairs public relations,
membership, jurisdiction, organizing, construction, maintenance,
and service trades, and others that work for the direct benefit
3 Respondent concedes that the activities of Mail Handlers
are not attributable to petitioner.
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