National Collegiate Athletic Ass'n v. Commissioner
United States Tax Court
P employed H as its agent to sell advertising to be published in programs for its annual men's basketball championship tournament. Held, P did not prove that the advertising sales activities were not "regularly carried on" or that the income constituted royalties. Thus, the income from the sales were subject to tax as unrelated business income. Secs. 511 through 513, I.R.C. 1954, as amended.
1Opinion of the Court
Cohen, Judge:
Respondent determined a deficiency of $10,395.14 in petitioner’s Federal income tax for 1982. The issues for decision are (1) whether income received by petitioner in connection with the publication of commercial advertisements in game programs for the 1982 Men’s Division 1 Basketball Championship Tournament was unrelated business taxable income under section 512,1 and if so, (2) whether such income is excludable from the unrelated business income tax as a royalty under section 512(b)(2).
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated facts are…
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