Ohio Farm Bureau Federation, Inc. - Page 13

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          services was substantially related to its tax-exempt purpose as             
          an agricultural organization under section 501(c)(5).                       
               For a substantial relationship to exist, the activity that             
          produces the income “must contribute importantly to the                     
          accomplishment of * * * [the organization’s exempt] purposes.”              
          Sec. 1.513-1(d)(2), Income Tax Regs.  The regulations describe              
          the type of relationship that qualifies as substantial:                     

               Trade or business is “related” to exempt purposes, in                  
               the relevant sense, only where the conduct of the                      
               business activities has causal relationship to the                     
               achievement of exempt purposes (other than through the                 
               production of income); and it is “substantially                        
               related,” for purposes of section 513, only if the                     
               causal relationship is a substantial one.  * * *  [Sec.                
               1.513-1(d)(2), Income Tax Regs.]                                       

          The substantial relationship requirement focuses upon the manner            
          in which the tax-exempt organization conducts its activities.               
          United States v. American College of Physicians, 475 U.S. 834,              
          848-849 (1986).                                                             
               In cases involving business leagues, courts have identified            
          two factual elements that are important to the substantial                  
          relationship determination:  (1) Whether the activities in                  
          question are “unique” to the organization’s tax-exempt function,            
          and (2) whether the activities benefit the common business                  
          interest of an organization’s membership or the industry as a               
          whole and not just members in their individual capacities.                  
          Professional Ins. Agents of Mich. v. Commissioner, 726 F.2d 1097,           





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