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167, 171 (4th Cir. 1983).
In the present case, the only fees paid to petitioner by its
members were membership dues. The benefits that petitioner’s
members might receive from petitioner’s educational, promotional,
and lobbying activities performed pursuant to the service
contract could turn out to be negligible, or they could far
outweigh the amount of their dues. The benefits were not
directly proportional to the amount of the fees paid. Moreover,
petitioner’s activities in lobbying for and promoting cooperative
activity would benefit the entire agricultural industry, not just
its members, and it is a service not commonly provided by for-
profit entities.
Respondent argues that, pursuant to the service contract,
petitioner agreed to promote exclusively Landmark and its
products and services, and that the manner in which petitioner
conducted its activities was primarily for the commercial benefit
of Landmark, rather than for the purposes underlying petitioner’s
exemption. Respondent cites Illinois Association of Professional
Ins. Agents v. Commissioner, supra and National Water Well
Association v. Commissioner, 92 T.C. at 97-98, to support her
argument.
In Illinois Association of Professional Ins. Agents v.
Commissioner, supra, the Court of Appeals for the Seventh Circuit
held that the manner in which the taxpayer, a business league
exempt under section 501(c)(6), conducted its errors and
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