2
Held, the income thus received from the long-
distance carriers for B & C services is income for the
performance of "communication services" within sec.
501(c)(12)(B)(i), and is therefore not taken into
account to comply with the "85 percent or more"
requirement of sec. 501(c)(12)(A). Accordingly, since
P is otherwise exempt from taxation under sec. 501(a),
it does not lose that exempt status.
Raymond P. Wexler, Todd F. Maynes, James M. Caplinger, and
Mark E. Caplinger, for petitioner.
Robin W. Denick, Elizabeth Purcell, and Robert M. Fowler,
for respondent.
OPINION
RAUM, Judge: The Commissioner determined deficiencies of
$170,686, $164,484, and $90,241 in petitioner's Federal income
taxes for 1991, 1992, and 1993, respectively. Petitioner, Golden
Belt Telephone Association, Inc., has filed a Motion for Summary
Judgment. The facts are not in dispute; the Government "does not
take issue with petitioner's statement of Uncontested Facts" set
forth in petitioner's motion, and adopted those facts in its own
"Motion for Partial Summary Judgment". Nor has the Government
disputed any facts stated in the "Preliminary Statement" of
petitioner's motion. At issue is whether income received by a
local telephone cooperative allocable to billing and collection
services performed in respect of long-distance calls qualifies as
income received for the performance of "communication services"
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