Sierra Club v. Commissioner
United States Tax Court
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
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Commissioner v. TowerSupreme Court of the United States · 1946
- 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
- Perlmutter v. CommissionerUnited States Tax Court · 1965
- Luna v. CommissionerUnited States Tax Court · 1964
20 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Common Cause v. CommissionerUnited States Tax Court · 1999
- Sierra Club v. CommissionerUnited States Tax Court · 1999
- Arkansas State Police Ass'n v. CommissionerUnited States Tax Court · 2001
- Common Cause v. CommissionerUnited States Tax Court · 1999
- Common Cause v. CommissionerUnited States Tax Court · 1999
5 more not listed; retrieve them via the Exa API.