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1103 (6th Cir. 1984), affg. 78 T.C. 246 (1982); Louisiana Credit
Union League v. United States, 693 F.2d 525, 535 (5th Cir.
1982).4
With respect to the uniqueness test, it has been stated
that:
Such services as educational and training programs,
legislative lobbying, and institutional advertising
clearly satisfy this uniqueness test, because they
advance the purposes of the * * * [organization] as an
entity in itself. It is the institutional ends that
must be served if the activity is to be deemed
substantially related. Educational, legislative, and
advertising services are peculiarly suitable activities
for a business league because they further the common
business interest that unites the association’s
members. * * * [Louisiana Credit Union League v.
United States, supra at 535; see also Professional Ins.
Agents of Mich. v. Commissioner, supra at 1103.]
Petitioner’s stated purpose was generally to aid and assist
in the betterment of the conditions and welfare of those engaged
in agriculture. The affidavit upon which petitioner’s tax
exemption was based defined petitioner’s purposes to include “the
sponsorship of * * * Purchasing and Marketing cooperatives”. The
primary thrust of petitioner’s activities under the service
contract was to educate Ohio farmers about agricultural
cooperatives in general, and Landmark specifically, and to
4While the cases cited deal with business leagues under sec.
501(c)(6), which are associations of persons having common
business interests, we have stated that this substantial
relationship analysis is relevant for purposes of sec. 501(c)(5)
agricultural organizations as well. California Thoroughbred
Breeders Association v. Commissioner, T.C. Memo. 1989-342.
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