Arkansas State Police Association, Inc. - Page 2




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               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.                                                                  
               After settlement of some issues, the issue for decision                
          involves whether payments petitioner received in connection with            
          advertising in a law-enforcement trade publication should be                
          treated under section 512(b)(2) as royalty payments and excluded            
          from petitioner's unrelated business taxable income.                        

                                     Background                                       
               This case was submitted fully stipulated under Rule 122, and           
          the facts are not in dispute.                                               
               Petitioner constitutes a not-for-profit corporation,                   
          organized under the laws of Arkansas and recognized under section           
          501(c)(5) as generally exempt from Federal income tax.                      
               Petitioner was formed for the purpose of, among other                  
          things, promoting impartial enforcement of law and order,                   
          increasing efficiency in the police profession, and cultivating a           
          spirit of fraternity and mutual helpfulness among and between the           
          Arkansas law enforcement community and the people of Arkansas.              
               During the years 1993 through 1996, under an agreement                 
          entitled “Royalties and Licensing Agreement” (the Agreement)                
          between petitioner and Brent-Wyatt West (BWW), an Arizona                   






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Last modified: May 25, 2011