- 37 - of its members, solicited and collected premiums from its members, sent premiums to the insurer, kept files on each policyholder, answered members' questions about insurance policies, and screened claims for benefits. Id. The Supreme Court found that this arrangement created unfair competition because ABE's members could deduct part of their premium payment as a charitable contribution. Unlike ABE, petitioner did not compete with any taxable entity; PB&T, not petitioner, competed with other credit card issuers. We conclude that petitioner did not engage in any activity which Congress intended to subject to the tax on unrelated business income. H. Conclusion Petitioner’s income from the affinity credit card program in the years in issue is a royalty excluded by section 512(b)(2) from the unrelated business income tax. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37
Last modified: May 25, 2011