Legal Opinion

Common Cause v. Commissioner

United States Tax Court

Decided June 22, 1999No. 13921-97Unknown

1Opinion of the Court

112 T.C. No. 23

UNITED STATES TAX COURT COMMON CAUSE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent1 Docket No. 13921-97. Filed June 22, 1999. P, an organization exempt from Federal income tax, receives payments from the rental of its mailing list. In each of P's list rental transactions, the mailer's rental payment compensates P for the mailer's use of P's list and, also, compensates a list broker, a list manager, and a computer house for their participation in the transaction. R determined that P's mailing list rental activities constitute an unrelated trade or business and that…

2Cases cited15 opinions

  1. Connecticut Mutual Life Insurance v. SpratleySupreme Court of the United States · 1899
  2. Board of Trade v. Hammond Elevator Co.Supreme Court of the United States · 1905
  3. Disabled American Veterans v. United StatesUnited States Court of Claims · 1981
  4. State Police Association of Massachusetts v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1997
  5. Ruge v. Comm'rUnited States Tax Court · 1956

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