Nos. 96-5026, 96-5027.

123 F.3d 1460 (1997)

MNOPF TRUSTEES LIMITED and Merchants Navy Ratings Pension Fund Trustees Limited, Plaintiffs/Cross-Appellants, v. The UNITED STATES, Defendant-Appellant,

United States Court of Appeals, Federal Circuit.

August 27, 1997.

Attorney(s) appearing for the Case

John V. Thornton, Whitman Breed Abbott & Morgan, New York City, argued, for plaintiffs/cross-appellants. On the brief was George J. Noumair.

Charles Bricken, Attorney, Tax Division, Department of Justice, Washington, DC, argued, for defendant-appellant. With him on brief were Loretta C. Argrett, Assistant Attorney General, Gary R. Allen, Chief, Appellate Section, and Gilbert S. Rothenberg, Attorney.

Before RICH, NEWMAN, and RADER, Circuit Judges.

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.

The issue...


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