- 12 - from the travel program. Petitioner allocated 5 percent of Wirth's salary and 50 percent of its secretary's salary to the travel program during the years at issue. H. Other Licensing Agreements and Proposals Petitioner entered into an agreement with Wayneco Enterprises, Inc. (Wayneco), on August 17, 1987. Wayneco agreed to provide class rings and commemorative watches to alumni and to pay petitioner $25 for each item purchased. Petitioner made no salary allocation for this agreement. Other organizations made proposals for similar programs to petitioner. Petitioner rejected the solicitations because they did not benefit petitioner's members or did not further petitioner's purpose. I. Petitioner's Income From the Affinity Credit Card Program Petitioner grossed $254,252 for 1990 and $357,998 for 1991 from the affinity credit card program. OPINION A. Taxation of Unrelated Business Income Section 511(a)(1) imposes a tax on the unrelated business taxable income (UBTI) of certain tax-exempt organizations. Petitioner is subject to tax on its unrelated business income under section 511(a)(2)(A) because it is tax exempt under section 501(c). Income is UBTI if: (1) The income arises from a trade or business; (2) the trade or business is regularly carried on;Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011