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STEAMSHIP TRADE ASS'N OF BALTIMORE, INC. v. COMMISSIONER

Docket No. 6051-81.

81 T.C. 303 (1983)

STEAMSHIP TRADE ASSOCIATION OF BALTIMORE, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 13, 1983.

Attorney(s) appearing for the Case

Neil S. Kurlander and A. Adgate Duer, for the petitioner.

Howard Philip Newman, for the respondent.

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...

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