PAULINE NEWMAN, Circuit Judge.
MNOPF Trustees Ltd. and Merchants Navy Ratings Pension Fund Trustees Ltd. (collectively "Merchants Navy") are trustees of pension funds of the British merchant marine. As labor organizations they are exempt from income taxation under 26 U.S.C. §§ 501(a) and 501(c)(5). They are foreign entities and have no business income in the United States, and thus are not required to file a United States income tax return.
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