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Revenue Procedure 95-21

1995-1 C.B. 686 (1995)

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Revenue Procedure 95-21

Internal Revenue Service
1995-1 C.B. 686 (1995)

Facts

A labor organization classified under § 501(c)(5) of the Internal Revenue Code generally had to include in its taxable income only revenue that was generated by a business unrelated to the organization’s tax-exempt purpose. Thus, labor organizations historically did not pay income tax on their membership dues. Some organizations began engaging in tax avoidance by carrying on businesses unrelated to the organizations’ tax-exempt purposes and labelling the fees people paid for goods or services as membership dues. The Internal Revenue Service (IRS) published a Revenue Procedure to publicize the IRS’s position on this practice.

Rule of Law

Issue

Holding and Reasoning ()

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