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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 to
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