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The organization in Texas Farm Bureau, in addition to
providing its logo, name, and mailing list, provided clerical and
administrative services, telephones, office supplies, and other
goods and services necessary to conduct an insurance business.
Texas Farm Bureau v. United States, supra at 123-124. In
Fraternal Order of Police v. Commissioner, supra, the taxpayer
published a magazine for which the taxpayer could appoint the
executive editor, prepare editorials and feature articles,
control solicitations of business listings and the bank account,
and decide whether an article appearing in the magazine could be
reprinted elsewhere. The U.S. Court of Appeals for the Seventh
Circuit held that the organization's income from business
listings was commercial advertising and was not a royalty because
the organization conducted it like a commercial venture. Id. at
723.
The taxpayer in Louisiana Credit Union League dealt with
commercial insurance vendors, debt collectors, and electronic
data processing services for its members. The U.S. Court of
Appeals for the Fifth Circuit said that the taxpayer--
did everything short of actually selling the insurance
and collecting the debts itself: it selected the
companies whose products and services would be
endorsed, actively marketed and promoted those products
and services to member credit unions, and performed the
day-to-day administrative tasks essential to the
insurance and debt collection operations. [Louisiana
Credit Union League v. United States, supra at 533.]
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