T.C. Memo. 1999-86
UNITED STATES TAX COURT
SIERRA CLUB, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 8650-91. Filed March 23, 1999.
On remand from the Court of Appeals for the Ninth
Circuit. Sierra Club, Inc. v. Commissioner, 86 F.3d
1526 (9th Cir. 1996), affg. in part, revg. in part
and remanding 103 T.C. 307 (1994) and T.C. Memo.
1993-199. The Court of Appeals remanded for findings
of fact whether P’s income from the affinity card
program, which was the subject of our report at 103
T.C. 307, constituted “royalties” within the meaning
of sec. 512(b)(2). Held, the receipts constitute
“royalties” within the meaning of sec. 512(b)(2).
Robert L. Dietz, and B. Holly Schadler, for petitioner.
* This report supplements our report in Sierra Club, Inc, v.
Commissioner, 103 T.C. 307 (1994), revd. and remanded 86 F.3d
1526 (9th Cir. 1996).
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