OPINION
SIMPSON, Judge:
The Commissioner determined a deficiency of $4,373 in the petitioner's Federal income tax for the fiscal year ended June 30, 1977. After a concession by the petitioner, the sole issue for decision is whether funds received by the petitioner from the collection of unpaid taxes for its members constitute unrelated business taxable income within the meaning of section 512(a)(1) of the Internal Revenue Code of 1954.
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