Court of Appeals for the Fourth Circuit June 14, 1996, 95-2646 (National League of Postmasters of the United States v. Commissioner of the Internal Revenue Service, American Farm Bureau Federation, Amicus Curiae)

OPINION

LAY, Senior Circuit Judge:

The National League of Postmasters (“the League”) is a tax-exempt labor organization under 26 U.S.C. § 501(c)(5). The Commissioner determined deficiencies in the League’s federal income taxes from 1987 to 1990 on the basis that dues and service fees the League received in relation to certain members, known as “League Benefit Members” (“LBMs”), were not