T.C. Memo. 1996-34
UNITED STATES TAX COURT
OREGON STATE UNIVERSITY ALUMNI ASSOCIATION, INC.,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No 2133-94. Filed January 30, 1996.
Philip N. Jones, Carolyn W. Miller, and Stephen J.
Klarquist, for petitioner.
Brenda M. Fitzgerald, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined deficiencies in
petitioner's Federal income tax of $89,590 for 1990 and $120,288
for 1991.
The issue for decision is whether petitioner's income from
an affinity credit card program is a royalty excluded by section
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