Alumni Association of the University of Oregon, Inc. - Page 18

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          disagree.  Petitioner's activities were de minimis and were done            
          to protect petitioner's goodwill with its members.                          
               In Sierra Club, Inc. v. Commissioner, supra, ABS promised              
          the cardholders that they would receive a rebate of the annual              
          fee if they participated in the program for a second year.  Id.             
          at 343.  ABS breached that agreement.  Id.  The Sierra Club                 
          helped arrange refunds to members.  Id.  We found that the Sierra           
          Club's actions were done to protect its good name.  Id.                     
          Similarly, petitioner was acting to preserve its good name with             
          alumni.                                                                     
               In Oregon State Univ. Alumni Association, Inc. v.                      
          Commissioner, T.C. Memo. 1996-34, we held that the taxpayer                 
          engaged in de minimis activity where it referred occasional                 
          requests for credit card applications or complaints about the               
          denial of a credit card application, told about 14 alumni to                
          contact its offices if they needed further assistance, and                  
          requested that USNB send preapproved applications to certain                
          alumni, expedite about eight applications, and establish some               
          credit limits above the standard.  Here, petitioner has engaged             
          in less activity than the taxpayer in Oregon State.  We hold that           
          USNB's payments to petitioner were not compensation for services            
          rendered and that petitioner's activities are compatible with the           
          treatment of those payments as royalty income.                              
               4.   Petitioner's Financial Risks and Rewards                          






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