Arkansas State Police Association, Inc. - Page 10




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          royalties.”  Id. at 136.  In the ruling, however, respondent also           
          stated that if members of a tax-exempt organization provide                 
          personal services in connection with the endorsement of the other           
          businesses' products, the payments received by the tax-exempt               
          organization would no longer qualify as royalties.  See id.                 
               Like the tax-exempt organizations in Fraternal Order of                
          Police v. Commissioner, supra, and State Police Association of              
          Massachusetts v. Commissioner, supra, petitioner herein                     
          significantly participated in and maintained control over                   
          significant aspects of the publication of TAT.  Petitioner                  
          possessed authority over the editorial content of TAT, and                  
          petitioner received and reviewed the articles, photographs,                 
          letters, and publicity for each edition of TAT.                             
               This case is dissimilar from the so-called affinity credit             
          card cases and mailing list cases in which tax-exempt                       
          organizations license their names to be used in the sale or                 
          promotion of another business' unrelated products (e.g., a credit           
          card company's credit) and in which it has been held that the               
          fees received by the tax-exempt organization qualified as exempt            
          royalty income.  See Sierra Club, Inc. v. Commissioner, supra;              
          Common Cause v. Commissioner, 112 T.C. 332 (1999); Mississippi              
          State Univ. Alumni, Inc. v. Commissioner, supra; Oregon State               
          Univ. Alumni Association, Inc. v. Commissioner, supra.                      








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