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