Carl & Ruth Briggs and Raymond J. Hurbi v. Commissioner of Internal Revenue

NORRIS, Circuit Judge:

Briggs and Hurbi (taxpayers) appeal from a judgment of the United States Tax Court, 75 T.C. 465, that union dues paid by the taxpayers and allocated for construction of recreation centers and distribution to a building fund were not deductible under I.R.C. § 162(a) (1976). We affirm.

Compulsory dues providing personal benefits to union members are non-deductible, see Rev.Rul. 78-128,1978-1 C.B. 39, and the determination of personal and business expenses turns on the purpose of the payments, see Rev.Rul. 81-192, 1981-31 C.B. 50. Thus, the payments in dispute are not…