BAUER, Chief Judge.
The Fraternal Order of Police ("FOP") appeals from a decision of the United States Tax Court that found FOP deficient in income tax payments for the taxable years September 30, 1976 through September 30, 1980.
The issues on appeal are whether income received from certain listings printed in The Trooper, a magazine published by FOP, constitute taxable income derived from an unrelated trade or business...
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