Oregon State University Alumni Association, Inc. - Page 2

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          512(b)(2) from the tax on unrelated business income.  We hold               
          that it is.                                                                 
               Section references are to the Internal Revenue Code in                 
          effect for the years in issue.  Rule references are to the Tax              
          Court Rules of Practice and Procedure.                                      
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          A.   Petitioner                                                             
               Petitioner, Oregon State University Alumni Association,                
          Inc. (OSUAA), is an Oregon nonprofit corporation exempt from                
          Federal income tax under section 501(c)(3).  Petitioner's                   
          principal place of business is Corvallis, Oregon.  Petitioner was           
          established to promote the interests and ideals of Oregon State             
          University (OSU), to stimulate and encourage loyalty in                     
          its students and former students, and to develop a sense of                 
          responsibility for continued progress in OSU educational                    
          programs.  Petitioner had 12 employees in 1989-90 and 13 in 1990-           
          91.                                                                         
          B.   History of the OSU Alumni Association Affinity Credit                  
               Card Program                                                           
               In 1986 and 1987, petitioner's executive director, Donald              
          Wirth (Wirth), became aware of affinity credit card programs                
          through news articles and contacts from other organizations.  The           
          executive director of the Alumni Association of the University of           
          Oregon (AAUO), Philip Super (Super), told Wirth about proposals             




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