No specific laws identified for this ruling.
P is a trust created under a collective bargaining agreement between the Teamsters Union (U) and the Contractors Association (A). When operational, P proposes to award grants to eligible employees and their families for the purpose of furthering their education. P's only source of funds is contributions received from members of A under the terms of the collective bargaining agreement. During the negotiations between A and U prior to the completion of the collective bargaining agreement, representatives of U requested the establishment of P as part of the allocation of an agreed financial settlement between wages and indirect compensation. Under the bargaining agreement, members of A are required to make contributions to P in the amount of 5 cents per hour of employment of covered employees; if contributions are not paid, members of U are authorized to strike. Held, because its primary purpose is to provide a form of indirect compensation to employees covered by the collective bargaining agreement, P is not operated \exclusively\ for any of the purposes described in sec. 501(c)(3), I.R.C. 1954, notwithstanding that P's proposed activities will to some extent further charitable purposes.
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Held: An amount received in settlement of a claim of race discrimination made pursuant to title VII of the Civil Rights Act of 1964 is not excludable from gross income pursuant to sec. 104(a)(2), I.R.C., as an amount received on account of personal injury. United States v. Burke, 504 U.S. , 112 S. Ct. 1867 (1992).
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