Steamship Trade Association of Baltimore, Inc. v. Commissioner of Internal Revenue

SPROUSE, Circuit Judge:

Steamship Trade Association of Baltimore, Inc. (STA), a tax-exempt business league, appeals from the decision of the Tax Court upholding the Internal Revenue Service’s determination that it was liable for taxes on unrelated business income for tax years 1975,1976, and 1977. Steamship Trade Association v. Commissioner, 81 T.C. 303 (1983). The income held to be taxable arose from STA’s retention of a portion of the funds it received from its members on behalf of longshoremen employees to fund guaranteed annual wage and vacation pay accounts established pursuant to…