16
should, in our judgment, be included as "communication services"
under section 501(c)(12). Accordingly, the income attributable
to such services should not be included in the 85-percent test.
As a consequence, more than 85 percent of petitioner's gross
income comes from member sources, and it therefore qualifies as a
tax-exempt entity.
Petitioner's motion for
summary judgment will be granted,
and decision will be entered
for petitioner. Respondent's
motion for partial summary judgment
will be denied.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Last modified: May 25, 2011