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omissions insurance activities indicated that the activities were
not substantially related to the taxpayer’s exempt purpose. The
court based its determination on the fact that the taxpayer
endorsed a particular errors and omissions program in a manner
that provided convenient marketing, advertising, and
administrative services to the insurance company and that
generated income for the taxpayer rather than educating the
taxpayer’s members, serving the public interest, or merely
advising of the need for such coverage. Illinois Association of
Professional Ins. Agents v. Commissioner, supra at 995. The
court further noted that the program benefited the individual
members in direct proportion to the fees they paid, rather than
benefiting the members as a group. Id.
Similarly, in National Water Well Association v.
Commissioner, supra, this Court held that the taxpayer’s
endorsement and sponsorship of a particular industry casualty
insurance program was not substantially related to its exempt
purpose. In so holding, we noted that had the taxpayer intended
to educate and advise its members of the need for casualty
industry insurance, it would have advised its members of various
types of insurance from which its members could select. National
Water Well Association v. Commissioner, supra at 98. Moreover,
only those individuals who paid premiums received insurance under
the industry casualty insurance program; therefore, the members
were not benefited as a group. Id. at 98-99.
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