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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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