Common Cause v. Commissioner
United States Tax Court
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.
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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 the list broker, the list manager, and the computer house are P's agents for the purpose of carrying on that business. R further determined that P's…
1Opinion of the Court
COMMON CAUSE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Common Cause v. Commissioner
No. 13921-97
United States Tax Court
112 T.C. 332; 1999 U.S. Tax Ct. LEXIS 26; 112 T.C. No. 23;
June 22, 1999, Filed
Decision will be entered for petitioner.
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…
2Cases cited16 opinions
- Connecticut Mutual Life Insurance v. SpratleySupreme Court of the United States · 1899
- Board of Trade v. Hammond Elevator Co.Supreme Court of the United States · 1905
- Disabled American Veterans v. United StatesUnited States Court of Claims · 1981
- State Police Association of Massachusetts v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1997
- Ruge v. Comm'rUnited States Tax Court · 1956
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