- 17 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011