Ohio Farm Bureau Federation, Inc. - Page 24

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               Accordingly, we hold that petitioner did not have UBTI                 
          during the taxable year in issue.9                                          


                                             Decision will be entered                 
                                        under Rule 155.                               


























          8(...continued)                                                             
          noncompetition does not constitute the carrying on of a trade or            
          business.”                                                                  
          9Because we have found that there was no underpayment of                    
          petitioner’s income tax, we need not address whether interest               
          should be computed under the provisions of sec. 6621(c), dealing            
          with large corporate underpayments.                                         




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