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STEAMSHIP TRADE ASS'N OF BALTIMORE, INC. v. C.I.R.

No. 84-1099.

757 F.2d 1494 (1985)

STEAMSHIP TRADE ASSOCIATION OF BALTIMORE, INC., Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Fourth Circuit.

Decided March 27, 1985.

Rehearing Denied May 6, 1985.

Attorney(s) appearing for the Case

Neil S. Kurlander, Baltimore, Md. (A. Adgate Duer, George M. Radcliffe, Niles, Barton & Wilmer, Baltimore, Md., on brief), for appellant.

David I. Pincus, Tax Div., Dept. of Justice, Washington, D.C. (Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Robert A. Bernstein, Washington, D.C., on brief), for appellee.

Before SPROUSE, CHAPMAN and SNEEDEN, Circuit Judges.

SPROUSE, Circuit Judge:

Steamship Trade Association of Baltimore, Inc. (STA), a tax-exempt business league, appeals from the decision of the Tax Court upholding the Internal Revenue Service's determination that it was liable for taxes on unrelated business income for tax years 1975, 1976, and 1977. Steamship Trade Association v. Commissioner, 81 T.C. 303 (1983). The income held to be taxable arose from STA's retention of a portion...

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