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.
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011