S.S. Trade Asso. v. Commissioner
United States Tax Court
Petitioner is a trade association of 49 employer-companies engaged in the business of maritime shipping and is exempt from tax as a business league under sec. 501(c)(6), I.R.C. 1954. Petitioner's exempt purpose is the promotion of labor-management harmony between its members and unions in the Port of Baltimore.
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Petitioner is a trade association of 49 employer-companies engaged in the business of maritime shipping and is exempt from tax as a business league under sec. 501(c)(6), I.R.C. 1954. Petitioner's exempt purpose is the promotion of labor-management harmony between its members and unions in the Port of Baltimore. During the years in issue, petitioner performed various administrative services with respect to the vacation pay and guaranteed annual income accounts provided for under the collective bargaining agreement. These activities include keeping track of how many hours each longshoreman…
1Opinion of the Court
Sterrett, Judge:
By notice of deficiency dated February 11, 1981, respondent determined deficiencies in petitioner’s Federal income taxes in the amounts of $149,318, $126,927, and $94,779 for the years 1975, 1976, and 1977, respectively. The sole issue for decision is whether petitioner’s administration and management of the vacation benefit fund and the guaranteed annual income fund constitute the conduct of an unrelated trade or business, thereby subjecting petitioner to the unrelated business income tax imposed by section 511, I.R.C. 1954.
FINDINGS OF FACT
Some of the facts have been…
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