MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined deficiencies in petitioner's Federal income tax of $13,374 for the tax year ending June 30, 1989, $20,059 for the tax year ending June 30, 1990, and $26,143 for the tax year ending June 30, 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 taxable...
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