Common Cause - Page 1

                                   112 T.C. No. 23                                    

                               UNITED STATES TAX COURT                                

                             COMMON CAUSE, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent1                     

               Docket No. 13921-97.               Filed June 22, 1999.                

                         P, an organization exempt from Federal                       
                    income tax, receives payments from the rental                     
                    of its mailing list.  In each of P's list                         
                    rental transactions, the mailer's rental                          
                    payment compensates P for the mailer's use of                     
                    P's list and, also, compensates a list                            
                    broker, a list manager, and a computer house                      
                    for their participation in the transaction.                       
                    R determined that P's mailing list rental                         
                    activities constitute an unrelated trade or                       
                    business and that the list broker, the list                       
                    manager, and the computer house are P's                           
                    agents for the purpose of carrying on that                        
                    business.  R further determined that P's                          
                    income from the rental of its mailing list is                     

          1    This case was consolidated, for trial purposes only, with              
          Planned Parenthood Fedn. of Am., Inc. v. Commissioner, T.C. Memo.           
          1999-206, in which an opinion is also being issued today.                   

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