MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined deficiencies in petitioner's Federal income tax of $89,590 for 1990 and $120,288 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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