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Rule references are to the Tax Court Rules of Practice and
Procedure.
The issues presented by the parties include: (1) Whether,
for purposes of the unrelated business income tax provisions of
section 511, petitioner is carrying on a list rental business
that is not substantially related to its exempt purpose; (2) if
so, whether the list brokers, list manager, and computer house
used by petitioner are agents of petitioner for the purpose of
carrying on such a business; and (3) whether the mailer's list
rental payments are royalties that are excluded from unrelated
business taxable income pursuant to section 512(b)(2).
FINDINGS OF FACT
Some of the facts and certain exhibits have been stipulated
for trial pursuant to Rule 91. The parties' stipulations of fact
are incorporated herein by reference and are found as facts in
the instant case.
Petitioner is a corporation with its principal office in
Washington, District of Columbia.
Petitioner is exempt from Federal income tax as an
organization described in section 501(c)(4). Petitioner was
formed for the purpose of improving governmental institutions,
processes, and policies by making them more responsive to the
needs of the Nation and the will of its citizens. Petitioner
maintains a list of names and addresses of its members, donors,
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Last modified: May 25, 2011