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parts of its donor list 451 times. Disabled Am. Veterans v.
Commissioner, 942 F.2d at 311. DAV continuously rented names
on its list during the years in issue. Disabled Am. Veterans v.
United States, 650 F.2d at 1184. In renting its donor list, DAV
followed the usual practices of the direct mail industry. Id.
DAV prepared rate cards showing the rates it charged to
customers. Id. It was widely known among list brokers that
DAV's mailing list was available for rental. Id. at 1185. DAV
employed two full-time employees to administer its list rentals.
Disabled Am. Veterans v. Commissioner, 942 F.2d at 311.
Petitioner's mailing list rental activity is unlike DAV's
rental activity. Petitioner received income from the use of its
mailing list only for: (a) Alumni trips in 1988, 1990, and 1991;
(b) alumni class rings and commemorative watches; and (c) the
affinity credit card program at issue here. Petitioner rejected
other proposals to use its mailing list because those proposals
did not benefit petitioner's members or further petitioner's
purpose.
Unlike DAV, petitioner did not regularly rent its mailing
list. Petitioner was not involved with the direct mail industry.
Petitioner did not issue rate cards. Petitioner used minimal
staff time to administer its list rentals. Petitioner allocated
15 percent of Wirth's salary to the affinity credit card program
in 1988 and 1989, and none for the years in issue. Petitioner
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