Legal Opinion

Sierra Club v. Commissioner

United States Tax Court

Decided March 23, 1999No. 8650-91UnpublishedCited by 1 opinion

On remand from the Court of Appeals for the Ninth Circuit. Sierra Club, Inc. v. Commissioner, 86 F.3d 1526 (9th Cir. 1996), affg. in part, revg. in part and remanding 103 T.C. 307 (1994) and T.C.

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On remand from the Court of Appeals for the Ninth Circuit. Sierra Club, Inc. v. Commissioner, 86 F.3d 1526 (9th Cir. 1996), affg. in part, revg. in part and remanding 103 T.C. 307 (1994) and T.C. Memo 1993-199. The Court of Appeals remanded for findings of fact whether P's income from the affinity card program, which was the subject of our report at 103 T.C. 307, constituted "royalties" within the meaning of sec. 512(b)(2). HELD, the receipts constitute "royalties" within the meaning of sec. 512(b)(2).

1Opinion of the Court

SIERRA CLUB, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent *

Sierra Club v. Commissioner

No. 8650-91

United States Tax Court

T.C. Memo 1999-86; 1999 Tax Ct. Memo LEXIS 101; 77 T.C.M. (CCH) 1569; T.C.M. (RIA) 99086;

March 23, 1999, Filed

Decision will be entered for petitioner.

On remand from the Court of Appeals for the Ninth Circuit.

Sierra Club, Inc. v. Commissioner, 86 F.3d 1526 (9th Cir. 1996),

affg. in part, revg. in part and remanding 103 T.C. 307 (1994)

and T.C. Memo 1993-199. The Court of Appeals remanded for

findings of fact whether P's income from the affinity card

program,…

2Cases cited6 opinions

  1. Phillips Petroleum Co. v. JonesCourt of Appeals for the Tenth Circuit · 1949
  2. Disabled American Veterans v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1991
  3. Sierra Club Inc. v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1996
  4. Disabled American Veterans v. CommissionerUnited States Tax Court · 1990
  5. Wm. J. Lemp Brewing Co. v. CommissionerUnited States Tax Court · 1952

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

3Cited by1 opinion

  1. New Jersey Council Of Teaching Hospitals v. CommissionerUnited States Tax Court · 2017

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