- 2 - 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 proposalsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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