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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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