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asserts that this was a service for which petitioner received
compensation under the credit card program. We believe that
that argument is more properly addressed to respondent's
conceded joint venture theory, and we fail to see how it
advances respondent's payment-for-services argument. We,
therefore, find that petitioner was not compensated for
services to the extent that it attempted to persuade Chase
Lincoln to relax its credit tolerances so that additional
credit cards could be issued and higher profits realized.
9. Conclusion
For the foregoing reasons, we conclude that none of the
receipts were in consideration for services provided by
petitioner as part of the credit card program. Rather, the
receipts were in consideration for the use of petitioner's
valuable intangible property, and, as such, constituted
"royalties" within the meaning of section 512(b)(2).
C. Subsequent Events
After the years here in question, ABS defaulted in its
obligations, petitioner terminated the SC-ABS agreement, and
entered into two agreements, the Termination Agreement and the
Bankcard Agreement (the two agreements), with Chase Lincoln.
The two agreements, among other things, establish a direct
relationship between petitioner and Chase Lincoln, provide for
the issuance of a new credit card not bearing petitioner’s
logo, and provide that petitioner would bear certain
advertising expenses. Whether amounts received in
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