Mississippi State University Alumni, Inc. - Page 28

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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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