Legal Opinion

Sierra Club v. Commissioner

United States Tax Court

Decided August 24, 1994No. Docket No. 8650-91PublishedCited by 10 opinions

This opinion (SC II) involves cross-motions for partial summary judgment made by the parties with respect to income generated through P's participation in an affinity credit card program. The respective motions arise subsequent to our disposition in Sierra Club, Inc. v. Commissioner, T.C. Memo. 1993-199 (SC I), of cross-motions for partial summary judgment with respect to income derived by P from the rental of its mailing lists.

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This opinion (SC II) involves cross-motions for partial summary judgment made by the parties with respect to income generated through P's participation in an affinity credit card program. The respective motions arise subsequent to our disposition in Sierra Club, Inc. v. Commissioner, T.C. Memo. 1993-199 (SC I), of cross-motions for partial summary judgment with respect to income derived by P from the rental of its mailing lists. P is an organization generally exempt from Federal income taxation under sec. 501(a), I.R.C., as an organization described in sec. 501(c)(4), I.R.C. P has assigned…

1Opinion of the Court

TABLE OF CONTENTS

Page

Introduction. 310

History of the Affinity Card Program . 311

Chase Lincoln. 311

Agreement with ABS . 311

ABS-Concept Agreement. 315

Concept-Chase Lincoln Agreement . 316

Amendment to ABS-Concept Agreement and

Concept-Chase Lincoln Agreement. 316

SC-Chase Lincoln Agreement . 317

ABS-Concept Modification . 317

Discussion. 317

I. Preliminary Matters .*.. 317

II. Motions for Partial Summary Judgment. 318

A. Petitioner’s Motion . 318

B. Respondent’s Motion . 318

C. Replies . 319

III. Analysis. 319

A. Business Arrangements . 319

1. Marketing Efforts . 319

2. Credit Cards . 320

3. Compensation of…

2Cases cited25 opinions

  1. Commissioner v. CulbertsonSupreme Court of the United States · 1949
  2. Commissioner v. TowerSupreme Court of the United States · 1946
  3. Ben Perlmutter and Bernice Perlmutter v. Commissioner of Internal Revenue, the Perlmutters, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1967
  4. Perlmutter v. CommissionerUnited States Tax Court · 1965
  5. Luna v. CommissionerUnited States Tax Court · 1964

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3Cited by10 opinions

  1. Common Cause v. CommissionerUnited States Tax Court · 1999
  2. Sierra Club v. CommissionerUnited States Tax Court · 1999
  3. Arkansas State Police Ass'n v. CommissionerUnited States Tax Court · 2001
  4. Common Cause v. CommissionerUnited States Tax Court · 1999
  5. Common Cause v. CommissionerUnited States Tax Court · 1999

5 more not listed; retrieve them via the Exa API.

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