The Direct TV Versus Dish Network Dilemma

Eenie meenie, miney mo - to which satellite TV service shall I go? Choosing between Direct TV (it is really called Directv) and the Dish Network is like deciding which political party is more corrupt than the other. It is all a matter of your perception of the programming and preference. Is one really better than the other? not really. They even have similar marketing promotions like a free satellite TV system when you purchase their satellite TV receiver or buy a certain programming package.

If you go by the number of customers alone, Directv would the outstanding choice. However, that is not necessarily true. They just have a lot more money to spend on advertising. How about price? Should you go by price alone to decide on a satellite dish network or a Direct satellite TV? The answer is no. Each of these satellite TV providers offers something a little different, which could make or break the choice, depending on preference. There is that pesky 'preference' thing again!

first of all, let us look at what they both have in common. Both companies present similar deals like free installation or a free satellite TV system. When it comes to movie and local television programming, the pricing is practically the same. Both the Dish Network and Direct TV offer DVR or digital video recording. With your Direct satellite TV however, you could upgrade to the Directv Tivo option for a nominal fee.

The differentiation is in the programming offered to subscribers. If you are aiming for a more international flavor, then the Dish Network would be your best bet. They have networks available in foreign markets that are broadcast in a variety of languages. So if you have transplanted yourself in the united States from somewhere else, chances are you might be able to catch the news and other shows from your homeland. Direct TV does have some foreign programming, mostly on the movie channels, but not the scope that the Dish Network offers.

now, Directv subscribers have a plethora of options when it comes to American sports. football, baseball, hockey, NASCAR ... these are important to sports fans. When the major sports have play-offs like the NFL or NBA, you can count on those rabid sports fans purchasing a 'pass' which buys a whole block of games. The Dish Network does offer sports, but they are more global in their choices. You will likely find rugby, lacrosse and soccer just as much as the football or baseball. They just don't have as much of a selection. So, if sports are your thing, then going for a Directv dish and satellite system is the best choice for you.

now you have a perspective from both sides of the two major satellite TV service providers. Both offer similar programming. It is choosing the little things that will influence your decision. Think about the Directv Tivo option. Think about the future possibility of Directv HDTV. If having these things in the future is important, then perhaps your mind is already made up, unlike that decision about which political party is more corrupt ...

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Does a Non-Profit 501(c)(3) Realize Unrelated Business Taxable Income (UBTI) For Advertising?

non-profit organizations which are exempt from income tax under 501(a) are subject to tax on unrelated business income. 501(b), 511. Unrelated business income is gross income derived by any organization from any unrelated trade or business, regularly carried on by it, less the deductions allowed. 512. An unrelated trade or business is a trade or business which is not substantially related (aside from the need of such organization for income or funds) to the purpose of the organization. 513. However, unrelated trade or business does not include a trade or business where substantially all the work is performed for the organization without compensation. 513(a)(1). see Rev. Rul. 75-201, 1975-1 CB 164.

The sale of advertising in a publication published by an exempt organization is an unrelated trade or business when the advertising activity is regularly carried on. Reg. 1.512(a)-1(f)(1). see also Rev. Rul. 73-424, 1973-2 CB 190.

Courts have held advertising revenue not to constitute unrelated business income in some circumstances. For example, in national Collegiate Athletic Assn. V. Comm., (1990, CA10) 66 AFTR 2d 90-5602, 914 F.2d 1417, 90-2USTC 50513, revg (1989) 92 TC 456, advertising revenue received by the NCAA from the sale of programs of its annually sponsored championship tournament was not unrelated business income where the tournament lasted less than three weeks and occurred only once a year.

IRS Chief Counsel strongly disagrees with the Tenth circuit. The IRS argues the state court should have taken into account the time spent soliciting the advertisements and preparing the advertising for publication. IRS announced it will continue to litigate the issue in appropriate cases. action on Decision 1991-015, 7/3/91.

IRS distinguished NCAA where a state university received income from advertising placed in its football souvenir programs. Here, a significant time span was involved over which the activities were conducted. The football season lasted three months and the work in setting up the programs and soliciting adverting took even longer. IRS letter ruling 9137002.

Assuming that the journal is published periodically throughout the year, an exempt organization should not rely on national Collegiate Athletic Assn. The periodic publishing and on going solicitation efforts will likely constitute a unrelated business regularly carried on. see 512.

The court also held advertising revenue does not constitute unrelated business income in US v. American college of Physicians, (1986 S.Ct). In American college of Physicians, the court found that the advertising business contributes importantly to the universitys education program through the training of students.

Also, advertising revenue does not constitute unrelated business income if the advertising contributes to the organizations purpose. For example, publication of legal notices in a bar association journal contributes to the associations exempt purposes by promoting the common interest of the legal profession through providing a single source of information regarding legal events in the county and therefore, wouldnt result in unrelated business income. Rev. Rul. 82-139, 1982-2 CB 108. However, advertising revenue received by a bar association for ads place in its attorney directory are taxable income since the advertising is commercial in nature and represents an effort on the part of advertisers to maximize sales to a certain segment of the public. IRS Letter Ruling 9148054.

Similarly, magazine advertising revenues received by an exempt trucking association did not contribute to the associations exempt purposes where the advertising represented marketing efforts by the advertisers to sell their product. In this case, no systematic effort was made by the organization to advertise products related to the editorial content and no effort was made by the organization to limit advertisements to new products. Florida Trucking Assn Inc. (1986) 87 TC 1039.

It is clear that, with a few exceptions, advertising revenues received by a 501(c)(3) exempt organization will often generate unrelated business taxable income (UBTI).

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FIFA World Cup 2006 England Glory - 1966 / 2006

It surely has a nice ring to it and would be a dream come true for the plethora of england fans who have never yet witnessed the creator of the beautiful game bring home the goods.

Although england have a pretty favourable group, with Paraguay, Trinidad & Tobago, and the dreaded Sweden; they will come through the group stages to the finals and then, with a bit of luck, stomp all over the opposition with verve and tenacity; if Wayne Rooney keeps his head that is.

As well as being a serious contender for the coveted golden boot Award, if england do indeed progress, Wayne Rooney is the key to Englands success in World cup 2006 and the rest of the team and world know it. The guy is a physiological freak in terms of the sheer power and depth of attack in his possession and will simply rip through the best defences that any of the worlds toughest may throw his way. He already proved this in Euro 2004, Portugal, where he was a constant worry for the opposition and, of course, does so every week at old Trafford.

Wayne Rooney is simply one man, though, and cannot do the job alone; he will need pace man magician michael Owen at his very best, beckham curling em in sweetly from the right, Frank Lampard bulldozing through the middle and Mr Sven Goran Eriksson not doing his usual trick of messing with formations and pulling off players at the wrong moment. In fact, england hasnt had such a brilliant compilation of players in years; its whether they can gel at the right time and do what the england rugby lads did in 2003.

One thing is certain though and perhaps will never change; anyone and everyone faced with england, ups their game rate by a noticeable margin. It seems that everyone wants to beat the Auld Enemy; hardly surprising beings as the country with the once largest of empires has, at one time or another, trounced on or been instrumental in shaping the modern world as we know it. It seems logical that someone would want to get their own back by beating the national football team.

many of the england naysayers believe that the england team lacks the personality and passion to bring home the cup. Although a personality is great for the cameras, the one ingredient that is surely more important is playing the game of football and scoring goals, and with the current england line up we have the best chance since 1966. Roll on World cup 2006

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