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Petitioner keeps a mailing list of MSU alumni so MSU and
petitioner can communicate with them. Petitioner has kept these
records on its computer since 1981. During the years in issue,
petitioner updated its alumni mailing list daily.
Petitioner reports to MSU's Office of University Relations,
which is headed by MSU's vice president for advancement.
Petitioner is exempt from Federal income tax under section
501(c)(3).
2. Petitioner's Employees
Petitioner had about 12 to 14 full-time employees from 1988
to 1991. Petitioner also employed students part time. MSU
generally paid petitioner's employees.
Steve C. Grafton (Grafton) was petitioner's executive
director from September 1987 to July 1994. He reported to MSU's
vice president for advancement and to petitioner's board of
directors. He usually worked 50 to 60 hours a week during the
years in issue.
Frances Carr (Carr) has worked for petitioner since around
1979. She processed annual fund gifts, made address changes on
the data base, and produced lists, labels, and diskettes during
the years in issue. Student employees assisted her during the
years in issue.
Petitioner hired a marketing coordinator in 1990. See
paragraph F, below.
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