- 2 - 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 ArizonaPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011