National League of Postmasters of the United States v. Commissioner of the Internal Revenue Service, American Farm Bureau Federation, Amicus Curiae
Court of Appeals for the Fourth Circuit
1Opinion of the Court
OPINION
LAY, Senior Circuit Judge:
The National League of Postmasters (“the League”) is a tax-exempt labor organization under 26 U.S.C. § 501(c)(5). The Commissioner determined deficiencies in the League’s federal income taxes from 1987 to 1990 on the basis that dues and service fees the League received in relation to certain members, known as “League Benefit Members” (“LBMs”), were not “substantially related” to any of the League’s tax-exempt purposes. See 26 U.S.C. § 513(a). The Tax Court upheld the Commissioner. We affirm.
Factual Background
In August of 1987, the League formed a new class of…
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