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
Wells, Judge:
Respondent determined deficiencies in petitioner’s Federal income taxes as follows:
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Unless otherwise indicated all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
The issues presented by the parties include: (1) Whether, for purposes of the unrelated business income tax provisions of section 511, petitioner is carrying on a list rental business that is not substantially related to its exempt purpose; (2) if so, whether the list brokers, list manager, and…
2Cases cited15 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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3Cited by8 opinions
- Oregon State University Alumni Association, Inc. v. Commissioner of Internal Revenue Service, Alumni Association of the University of Oregon, Inc. v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1999
- Oregon State University Alumni Ass'n v. CommissionerCourt of Appeals for the Ninth Circuit · 1999
- Arkansas State Police Ass'n v. CommissionerUnited States Tax Court · 2001
- Bellco Credit Union v. United StatesDistrict Court, D. Colorado · 2009
- Bellco Credit Union v. United StatesDistrict Court, D. Colorado · 2010
3 more not listed; retrieve them via the Exa API.