- 24 - received by the contributor had a value less than the amount of the contribution given in exchange for the display or listing. Consequently, we will apply an analysis of the displays and listings similar to the one we used in Fraternal Order of Police v. Commissioner, 87 T.C. 747 (1986), to decide whether petitioner's displays and listings in The Constabulary constitute "advertising". As in Fraternal Order of Police, the displays in The Constabulary contained the usual elements associated with advertisements such as blocking, illustrations, signatures, trademarks, and emblems. An "Advertisers’ Index" contained the name of the sponsor of each display, including McDonald's, AT&T Corp., John Hancock, Sheraton Hotels, and Mobil Oil Corp., among other well-known companies, and specified the page upon which the display was located. Between the displays and the "Advertiser’s Index" appeared a section of listings called the Business Directory wherein various businesses were identified by name and classified by type of business, as in the yellow pages of a telephone directory. We have examined the record and copies of The Constabulary, and we are convinced that both the displays and the listings constitute "advertising". Many of the displays are composed of slogans, logos, trademarks, and other information which is similar if not identical in content, composition, and message toPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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