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NEA. v. COMMISSIONER

Docket No. 22838-09.

137 T.C. 100 (2011)

NATIONAL EDUCATION ASSOCIATION OF THE UNITED STATES, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed September 28, 2011.

Attorney(s) appearing for the Case

Miriam L. Fisher and Theodore J. Wu , for petitioner.

Robin W. Denick and Catherine R. Chastanet , for respondent.

GUSTAFSON, Judge:

Petitioner National Education Association of the United States ("NEA") is a labor organization described in section 501(c)(5).1 It is therefore generally exempt from Federal income tax under section 501(a); but to the extent it engages in income-generating activity unrelated to its tax-exempt purposes, it is potentially liable under sections 511 through 513 for unrelated business income tax ("UBIT"). NEA publishes...

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