Veterans of Foreign Wars, Dep't of Michigan v. Commissioner
United States Tax Court
Petitioner is a veterans' organization exempt from income tax by sec. 501(a), I.R.C. 1954. Petitioner operated an annual Christmas card program which consisted of contracting with a third party to have a package of Christmas cards sent to each of petitioner's members who appeared on a list supplied by petitioner.
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Petitioner is a veterans' organization exempt from income tax by sec. 501(a), I.R.C. 1954. Petitioner operated an annual Christmas card program which consisted of contracting with a third party to have a package of Christmas cards sent to each of petitioner's members who appeared on a list supplied by petitioner. Accompanying the packages of Christmas cards were materials soliciting funds in suggested amounts of $ 2 for 1975, and $ 3 for 1976 and 1977. Any member who did not participate in the Christmas card program for 3 consecutive years was dropped from the list. The list was updated 3…
1Opinion of the Court
CHABOT, Judge-.
Respondent determined deficiencies in Federal unrelated business income tax (sec. 5111 et seq.) against petitioner as follows:
Taxable year 2 Amount
1975 .$6,157
1976. 7,351
1977. 7,317
After concessions by respondent, the issue for decision is whether certain amounts received by petitioner constitute unrelated business taxable income.
FINDINGS OF FACT
Some of the facts have been stipulated; the stipulations and the stipulated exhibits are incorporated herein by this reference.
When the petition was filed in the instant case, petitioner’s principal place of business was in Lansing,…
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