Golden Belt Telephone Association, Inc. - Page 16

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          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.                               


























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