912--LIGHT 351-362
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NOTES 351 Tax Lawyer, Vol. 55, No. 1 NOTE DENIAL OF THE ROYALTY EXCLUSION BECAUSE OF EXCESSIVE PARTICIPATION IN ARKANSAS STATE POLICE ASSOCIATION V. COMMISSIONER In Arkansas State Police Ass’n v. Commissioner,1 the Tax Court held that payments made to the Arkansas State Police Association (Association) by a magazine publisher out of advertising revenue did not qualify as royalties under section 512(b)(2)2 of the Code and were required to be included in the Association’s computation of unrelated...