Mississippi State University Alumni, Inc. - Page 37

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          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.                                                     

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