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ALUMNI ASSOCIATION OF THE UNIVERSITY OF OREGON, INC. v. COMMISSIONER

Docket No. 2132-94.

71 T.C.M. 2093 (1996)

T.C. Memo. 1996-63

Alumni Association of the University of Oregon, Inc. v. Commissioner.

United States Tax Court.

Filed February 20, 1996.

Attorney(s) appearing for the Case

Philip N. Jones, Portland, Ore., Carolyn W. Miller, and Stephen J. Klarquist, for the petitioner. Brenda M. Fitzgerald, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined deficiencies in petitioner's Federal income tax of $75,588 for 1990 and $105,183 for 1991.

The issue for decision is whether petitioner's income from an affinity credit card program is a royalty excluded by section 512(b)(2) from the tax on unrelated business income. We hold that it is.

Section references are to the Internal Revenue Code in effect for the years in...

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