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from tax-deductible donations, respondent’s position implies that
any transfer by an exempt organization to a taxable corporation
would create a private benefit or inurement problem. We reject
this position. Accordingly, we hold that petitioner’s operation
does not result in an impermissible private benefit to the
University and that petitioner’s net earnings do not inure to the
University.
To reflect the foregoing,
Decision will be entered
for petitioner.
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