- 25 - We disagree with respondent's contention that petitioner was unfairly competing with taxed businesses. C. Conclusion For the foregoing reasons, we hold that petitioner's income from the affinity credit card program is a royalty for purposes of section 511. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Last modified: May 25, 2011