Ohio Farm Bureau Federation, Inc. - Page 16

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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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