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NATIONAL COLLEGIATE ATHLETIC ASS'N v. COMMISSIONER

Docket No. 24889-87.

92 T.C. 456 (1989)

NATIONAL COLLEGIATE ATHLETIC ASSOCIATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 28, 1989.

Attorney(s) appearing for the Case

George H. Gangwere, C. W. Crumpecker, Jr., and Randal O. Carlson, for the petitioner.

Robert M. Fowler, for the respondent.

COHEN, Judge:

Respondent determined a deficiency of $10,395.14 in petitioner's Federal income tax for 1982. The issues for decision are (1) whether income received by petitioner in connection with the publication of commercial advertisements in game programs for the 1982 Men's Division 1 Basketball Championship Tournament was unrelated business taxable income under section 512,1 and if so, (2) whether such income is excludable from...

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