State Police Ass'n v. Commissioner
United States Tax Court
[Code Sec. 512] Exempt organization: Solicitation program: Advertising activity: Unrelated business taxable income: Low-cost article exemption. -- Amounts generated by an exempt labor organization's solicitation program for its annual "yearbook" constituted income from the sale of advertising as a trade or business. Thus, the organization was liable for the unrelated business income tax.
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[Code Sec. 512] Exempt organization: Solicitation program: Advertising activity: Unrelated business taxable income: Low-cost article exemption. -- Amounts generated by an exempt labor organization's solicitation program for its annual "yearbook" constituted income from the sale of advertising as a trade or business. Thus, the organization was liable for the unrelated business income tax. The displays and listings that appeared in the book constituted advertising since they contained slogans, logos, trademarks, and other information similar to advertisements found in other professional…
1Opinion of the Court
State Police Association of Massachusetts v. Commissioner.
State Police Ass'n v. Commissioner
Docket No. 15443-93.
United States Tax Court
T.C. Memo 1996-407; 1996 Tax Ct. Memo LEXIS 452; 72 T.C.M. (CCH) 582;
September 4, 1996, Filed [Appealable, barring stipulation to the contrary, to CA-1. -- CCH.]
Decision will be entered under Rule 155.
[Code Sec. 512]
Exempt organization: Solicitation program: Advertising activity: Unrelated business taxable income: Low-cost article exemption. -- Amounts generated by an exempt labor organization's solicitation program for its annual "yearbook" constituted income…
2Cases cited17 opinions
- Connecticut Mutual Life Insurance v. SpratleySupreme Court of the United States · 1899
- Woods v. CommissionerUnited States Tax Court · 1989
- Adler v. CommissionerUnited States Tax Court · 1985
- Metra Chem Corp. v. CommissionerUnited States Tax Court · 1987
- Johnny Spain v. Ruth L. Rushen, Director, California Department of CorrectionsCourt of Appeals for the Ninth Circuit · 1989
12 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- State Police Association of Massachusetts v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1997
- United States v. KremetisCourt of Appeals for the First Circuit · 1997
- United States v. KremetisCourt of Appeals for the First Circuit · 1997