Planned Parenthood Federation of America, Inc. - Page 2




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                              1993      49,210                                        
               Unless otherwise indicated all section references are to the           
          Internal Revenue Code in effect for the years in issue, and all             
          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 managers, 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               
          New York, New York.                                                         
               Petitioner is exempt from Federal income tax as an                     
          organization described in section 501(c)(3).  Petitioner was                
          formed for the purpose of assuring quality reproductive health              
          care for women.  Petitioner maintains a list of names and                   



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