Memorandum Findings of Fact and Opinion
COLVIN, Judge:
Respondent determined a deficiency of $11,454 for taxable year 1984. The issues for decision are:
(1) Whether petitioner, a labor organization, is liable for tax under section 527(b) and (f) as the result of its 1984 transfer of $25,000 to its separate segregated political organization account. We hold that it is.
(2) Whether petitioner can, in effect, reverse the transaction and avoid...
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