Oregon State University Alumni Association, Inc. - Page 1

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                                 T.C. Memo. 1996-34                                   


                               UNITED STATES TAX COURT                                


                 OREGON STATE UNIVERSITY ALUMNI ASSOCIATION, INC.,                    
             Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent               


               Docket No 2133-94.                Filed January 30, 1996.              


               Philip N. Jones, Carolyn W. Miller, and Stephen J.                     
          Klarquist, for petitioner.                                                  
               Brenda M. Fitzgerald, for respondent.                                  


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
          COLVIN, Judge:  Respondent determined deficiencies in                       
          petitioner's Federal income tax of $89,590 for 1990 and $120,288            
          for 1991.                                                                   
               The issue for decision is whether petitioner's income from             
          an affinity credit card program is a royalty excluded by section