National Education Association of the United States v. Comr., 137 T.C. 100 (2011)

(petitioner, a tax-exempt labor organization, publishes two magazines for its membership and derives unrelated business income of approximately $8 million from sale of ads; petitioner deducted circulation costs of approximately $7 million, but IRS disallowed the deduction because the magazines were available to all members which required petitioner to allocated portion of dues income to magazine income resulting in tax liability of $1.1 million; court agreed with IRS - NEA members had right to receive the magazine because their dues paid for it.).