RALPH B. GUY, Jr., Circuit Judge.
The Commissioner of Internal Revenue (CIR) appeals an adverse judgment of the United States Tax Court, finding that Disabled American Veterans (DAV), a tax-exempt organization, did not have tax deficiencies over the ten-year period, 1974-85.
CIR raises two issues on appeal: whether monies received by DAV from other organizations for the use of names from DAV's donor list are excludable from unrelated business taxable income...
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