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. 1954. 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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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