Planned Parenthood Federation of America, Inc. - Page 30




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                    I also have discussed with Congressman Duncan [(R-                
               Tenn.) Ranking Republican Member of the Ways and Means                 
               Committee] the issue of whether the provision of the                   
               bill which excludes certain income from unrelated trade                
               or business income creates any inference under present                 
               law.  We have reached a common understanding regarding                 
               the following specific issue:                                          
                    The question relates to section 1601 of the bill which            
               excludes from unrelated trade or business income revenues              
               from the use of a tax-exempt organization's mailing list by            
               another such organization.  Section 1601 of the bill, which            
               specifically exempts certain such revenues from the tax on             
               unrelated business income in the future, carries no                    
               inference whatever that mailing list revenues beyond its               
               scope or prior to its effective date should be considered              
               taxable to an exempt organization.  [132 Cong. Rec. 26208              
               (Sept. 25, 1986).]                                                     
          Additionally, the General Explanation provided by the Staff of              
          the Joint Committee on Taxation explains:  "No inference is                 
          intended as to whether or not revenues from mailing list                    
          activities other than those described in the provision, or from             
          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.11                                                                  


          11   Respondent also contends that the list rental payments                 
                                                             (continued...)           





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