United Cancer Council, Inc. - Page 1

                                   109 T.C. No. 17                                    

                               UNITED STATES TAX COURT                                

                     UNITED CANCER COUNCIL, INC., Petitioner v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 2008-91X.             Filed December 2, 1997.               

                    Petitioner was organized in 1963.  In a ruling letter             
               dated Mar. 31, 1969, respondent ruled that petitioner was              
               exempt from Federal income tax and was an eligible                     
               charitable donee.  Secs. 501(a), 501(c)(3), 170(c), I.R.C.             
                    On June 11, 1984, petitioner entered into a 5-year                
               fundraising contract (the Contract) with a professional                
               fundraiser (W&H).  During 1984 through 1989, W&H helped                
               petitioner conduct a nationwide direct mail fundraising                
               campaign.  Petitioner received a total of about $2� million            
               in net fundraising revenue under the Contract.  W&H received           
               more than $4 million in fees from petitioner, and in                   
               addition derived substantial income from exploiting the co-            
               ownership rights in petitioner’s mailing list, which rights            
               had been granted to W&H under the Contract.                            
                    On Nov. 2, 1990, respondent revoked the favorable                 
               ruling letter retroactively to June 11, 1984.  Petitioner              
               initiated the instant action under sec. 7428, I.R.C. 1986,             
               for a declaratory judgment that it qualifies as an exempt              
               organization and as an eligible charitable donee.                      

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