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because Grafton projected that the person hired could generate
enough funds to pay his or her own salary. We disagree. It is
not surprising that the marketing coordinator for a fundraising
organization would raise more money than he or she was paid.
Respondent contends that Andrews regularly devoted a
substantial amount of time to the credit card program. We
disagree. Andrews, Grafton, and Brown testified without
contradiction that Andrews worked only a negligible amount of
time on the credit card program.
Andrews' effort to sell advertising for the credit card
program to PB&T was not a service to PB&T; it was an effort to
increase petitioner's advertising revenue. Respondent implies
that the fact that Andrews suggested changes to the 1987
agreement so petitioner could get more use from the message
included in the monthly billing statement and contacted other
universities to seek ideas for the addendum for the 1991 contract
were services for PB&T. We disagree; this was work she did to
assist petitioner in its dealings with PB&T.
5. Endorsement and Review of Marketing Materials
Respondent points out that petitioner endorsed the program
and reviewed marketing materials prepared by PB&T. Respondent
contends that these actions were services to PB&T for purposes of
section 512(b). We disagree.
PB&T or advertising firms hired by PB&T wrote endorsement
messages over a facsimile of Grafton's signature which were
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