Nat'l Educ. Ass'n of the United States v. Comm'r
United States Tax Court
P is a tax-exempt labor organization described in I.R.C. sec. 501(c)(5). In its FYE Aug. 31, 2001, 2002, and 2003, P published two magazines at an expense of about $7 million, and it distributed those magazines to dues-paying members and to a very few non-member paying subscribers. P's literature and that of its State and local affiliates stated that members received the magazines as a benefit of membership and stated an amount of dues that paid for the magazines.
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P is a tax-exempt labor organization described in I.R.C. sec. 501(c)(5). In its FYE Aug. 31, 2001, 2002, and 2003, P published two magazines at an expense of about $7 million, and it distributed those magazines to dues-paying members and to a very few non-member paying subscribers. P's literature and that of its State and local affiliates stated that members received the magazines as a benefit of membership and stated an amount of dues that paid for the magazines. Members who declined the magazines did not pay a smaller amount of dues. P made most but not all of the content of the magazines…
1Opinion of the Court
Gustafson, Judge:
Petitioner National Education Association of the United States (“NEA”) is a labor organization described in section 501(c)(5). 1 It is therefore generally exempt from Federal income tax under section 501(a); but to the extent it engages in income-generating activity unrelated to its tax-exempt purposes, it is potentially liable under sections 511 through 513 for unrelated business income tax (“ubit”). NEA publishes magazines mainly for its members (an activity “related” to its exempt purposes and not subject to ubit) and sells advertising in those magazines (an “unrelated”…
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- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
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3Cited by1 opinion
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