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regularly carried on. The regulations provide the general
requirement:
In determining whether trade or business from which a
particular amount of gross income derives is "regularly
carried on," within the meaning of section 512, regard
must be had to the frequency and continuity with which
the activities productive of the income are conducted
and the manner in which they are pursued. * * * [Sec.
1.513-1(c)(1), Income Tax Regs.]
The regulations also provide that "This requirement must be
applied in light of the purpose of the unrelated business income
tax to place exempt organization business activities upon the
same tax basis as the nonexempt business endeavors with which
they compete." Id.
After stating the general principles, the regulations next
categorize an exempt organization’s business on the basis of its
nonexempt counterparts’ "Normal time span of activities." Sec.
1.513-1(c)(2)(i), Income Tax Regs. The regulations inquire
whether the exempt organization’s income-producing activities are
of a kind normally conducted by nonexempt commercial
organizations on (1) a year-round basis or (2) only a seasonal
basis. Id. For "year-round" activities, the regulations provide
that "the conduct of such activities by an exempt organization
over a period of only a few weeks does not constitute the regular
carrying on of trade or business", but that the conduct of such
activities "for one day each week would constitute the regular
carrying on of trade or business." Id. For "seasonal"
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