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.
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