- 18 - 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 RewardsPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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