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mailing list activities described in the provision, but occurring
prior to the effective date, constitute unrelated business
income." Staff of Joint Comm. on Taxation, General Explanation
of the Tax Reform Act of 1986, at 1325 (J. Comm. Print 1987). We
conclude that the enactment of section 513(h) does not require
that we hold that the revenues from the rental of petitioner's
mailing list during the years in issue are UBTI and thus subject
to UBIT.7
We have considered the parties' remaining arguments and
conclude that they are without merit, irrelevant, or unnecessary
to reach.
To reflect the foregoing,
Decision will be entered
for petitioner.
7 Respondent also contends that the list rental payments
cannot be royalties because petitioner paid "development" or
"production" costs. Respondent borrows those terms from the
mineral royalty context, and we conclude that they are not
helpful to our inquiry.
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