- 24 - 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.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
Last modified: May 25, 2011