State Police Association of Massachusetts v. Commissioner of Internal Revenue

SELYA, Circuit Judge.

In this case, the Commissioner of the Internal Revenue Service (the Commissioner) issued a deficiency notice to the State Police Association of Massachusetts (the Association) for income taxes allegedly- due but unpaid. When the Association protested, the Tax Court sided with the Commissioner. See State Police Ass’n of Mass. v. Commissioner, 72 T.C.M. (CCH) 582 (1996) (Tax Ct.Op.). The Association appeals, contending that the Tax Court erred both in finding that the deficiency assessment was timely and in holding that certain of the Association’s activities gave rise to…