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that was contributed, we believe that the conclusions of
petitioner's expert are based upon incomplete information.
Accordingly, we discount the testimony of petitioner's expert.
Petitioner next argues that one factor to be used in
determining the existence of "advertising" is the contributor's
intent in making a payment to the organization. Petitioner
argues that contributors to The Constabulary expected no
commercial benefit from their payment but merely intended to
benefit petitioner. In its affirmance of our decision in
Fraternal Order of Police v. Commissioner, supra, the Seventh
Circuit Court of Appeals stated that the sponsor's
motivation [to help support the families of officers
killed in the line of duty] does not define * * * [the
Fraternal Order of Police's] activities. To place a
listing in The Trooper, each sponsor had to purchase a
space and pay a prescribed rate which corresponded to
the desired size of the listing. Moreover, each issue
of The Trooper included the request by the editors that
its readers patronize those who had paid for the
listings. [Fraternal Order of Police v. Commissioner,
833 F.2d at 721.]
Accordingly, in the instant case, we conclude that an inquiry
into the contributor's intent in making a payment to petitioner
is not helpful in light of the fact that the contributors
received the displays and listings in consideration of their
contribution; i.e., they purchased the display or listing, and
the size of the space allotted to the contributor's message was
linked to the amount paid. In any event, petitioner has not
established in the instant case that the display or listing
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