LABORERS' INT'L UNION OF NORTH AMERICA v. COMMISSIONER

2001 T.C. Memo. 171, 82 T.C.M. 158, 170 L.R.R.M. (BNA) 3083, 2001 Tax Ct. Memo LEXIS 201
CourtUnited States Tax Court
DecidedJuly 9, 2001
DocketNo. 910-00
StatusUnpublished

This text of 2001 T.C. Memo. 171 (LABORERS' INT'L UNION OF NORTH AMERICA v. COMMISSIONER) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
LABORERS' INT'L UNION OF NORTH AMERICA v. COMMISSIONER, 2001 T.C. Memo. 171, 82 T.C.M. 158, 170 L.R.R.M. (BNA) 3083, 2001 Tax Ct. Memo LEXIS 201 (tax 2001).

Opinion

LABORERS' INTERNATIONAL UNION OF NORTH AMERICA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
LABORERS' INT'L UNION OF NORTH AMERICA v. COMMISSIONER
No. 910-00
United States Tax Court
T.C. Memo 2001-171; 2001 Tax Ct. Memo LEXIS 201; 82 T.C.M. (CCH) 158; 170 L.R.R.M. 3083;
July 9, 2001, Filed

*201 Decision will be entered for petitioner.

Stephen M. Feldhaus, Jasper G. Taylor III, and Richard L. Hunn,
for petitioner.
Stephanie L. Caden and Elizabeth S. Henn, for respondent.
Laro, David

LARO

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, JUDGE: Respondent determined that petitioner had unrelated business taxable income (UBTI) under section 511(a)1 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  *202     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 FACT 2

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*203 under an "Agreement of Affiliation". Mail Handlers is a separate, autonomous division of petitioner with many affiliated local unions. Unlike other formerly independent national unions that have become subordinate bodies of petitioner, the national identity of Mail Handlers was retained. Mail Handlers and its affiliated local unions were not integrated into petitioner's organizational structure.

Mail Handlers has two categories of members, regular and associate members. Upon payment of a fee to Mail Handlers, associate members are entitled to participate in Mail Handlers' health plan. The primary reason that individuals become Mail Handlers' associate members is to participate in its health plan. The associate members of Mail Handlers are not members of, associates of, or otherwise affiliated with petitioner. Mail Handlers' associate members are not entitled to any right, privilege, or benefit from petitioner. In the subject years, petitioner did not provide any benefit or service to Mail Handlers' associate members.

Mail Handlers collects dues from its associate members through a national uniform billing program. Mail Handlers retains part of those dues and remits the rest to local*204 unions.

For all years in issue, petitioner did not itself operate, 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*205 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 of all its affiliated bodies and regular members, acting as an appellate body to resolve internal disputes among the affiliated bodies and between regular members and affiliated bodies, and negotiating and administering national collective bargaining agreements in numerous industries that provide job opportunities for regular members, and that are serviced by local union and district councils in coordination with the Mail Handlers. The above-listed activities benefited Mail Handlers during the years in issue.

OPINION

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Bluebook (online)
2001 T.C. Memo. 171, 82 T.C.M. 158, 170 L.R.R.M. (BNA) 3083, 2001 Tax Ct. Memo LEXIS 201, Counsel Stack Legal Research, https://law.counselstack.com/opinion/laborers-intl-union-of-north-america-v-commissioner-tax-2001.