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the listings found in other professional journals, newspapers,
and the yellow pages of telephone directories. Additionally, the
contracts with BWE and McKnight, petitioner's correspondence, and
The Constabulary itself repeatedly use such words and phrases as
"advertising", "advertisements", "advertisers", "ad book", and
"marketing advertising" to describe the displays and listings and
related activities. Consequently, we conclude that the displays
and listings in The Constabulary constitute "advertising".
Petitioner next argues that section 1.513-1(b), Income Tax
Regs., exempts its solicitation activity from being characterized
as a trade or business because its "advertising" is a low-cost
article. That regulation addresses charitable fundraising
programs where low-cost goods are sent out by organizations along
with a solicitation to contribute money. In its sales of
advertising, however, petitioner did not follow such a procedure.
Additionally, the lowest charge for any of petitioner’s displays
or listings was, during some of the periods in issue, $55 for a
two-line listing in the business directory, a cost that cannot be
properly described as "low". Accordingly, we conclude that
petitioner is not eligible for the low-cost article exemption.
We next examine whether petitioner's selling of advertising
space constitutes an "unrelated trade or business" for purposes
of section 512. Generally, the selling of advertising space is
an "activity which is carried on for the production of income
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