Fraternal Order of Police Illinois State Troopers Lodge No. 41 v. Commissioner
United States Tax Court
Petitioner, an exempt organization under sec. 501(c)(8), I.R.C. 1954, published The Trooper magazine. In addition to articles relating primarily to the duties of police officers, The Trooper contained two types of business listings covering a wide range of professional, consumer, and leisure products and services. The first type, the business directory, classified and arranged the listers in the same manner as the yellow pages of a telephone directory.
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Petitioner, an exempt organization under sec. 501(c)(8), I.R.C. 1954, published The Trooper magazine. In addition to articles relating primarily to the duties of police officers, The Trooper contained two types of business listings covering a wide range of professional, consumer, and leisure products and services. The first type, the business directory, classified and arranged the listers in the same manner as the yellow pages of a telephone directory. The second type, referred to as "large listings" contained the usual elements of advertisements such as blocking, illustrations, signatures,…
1Opinion of the Court
SHIELDS, Judge:
Respondent determined deficiencies in petitioner’s income tax as follows:
Year ended Sept. 30— Deficiency
1976. $65,769.80
1977. 83,174.05
1978. 42,677.52
1979. 47,620.63
1980. 94,353.90
The issue for decision is whether the receipts of petitioner generated by certain listings in The Trooper magazine constitute income derived from an unrelated trade or business under section 511,1 and if so, whether such receipts are excludable from unrelated business taxable income as royalties under section 512(b)(2).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The…
2Cases cited14 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
- C. F. Mueller Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1951
- Roche's Beach, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1938
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3Cited by28 opinions
- State Police Association of Massachusetts v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1997
- Fraternal Order of Police, Illinois State Troopers, Lodge No. 41, Petitioner v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1987
- National Water Well Ass'n v. CommissionerUnited States Tax Court · 1989
- Disabled American Veterans v. CommissionerUnited States Tax Court · 1990
- National Collegiate Athletic Ass'n v. CommissionerUnited States Tax Court · 1989
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