6 Petitioners filed Forms 990, Returns of Organization Exempt from Income Tax, for the years in issue. ACADA and WSA reported using the cash receipts and disbursements method of accounting, and FSEP reported using the accrual method of accounting. On Form 990 filed for the tax year 1989, WSA reported proceeds from dauber sales in the amount of $29,449.11 and from cafeteria sales in the amount of $6,193.99, in addition to proceeds from bingo games. Petitioners did not file Forms 990T, Exempt Organization Business Income Tax Returns, during the years in issue. In the notices of deficiencies, respondent determined that petitioners were liable for tax on UBTI with respect to petitioners' "instant bingo" activities. Respondent allowed deductions for prizes paid and expenses paid related to petitioners' "instant bingo" activities in computing petitioners' UBTI. Respondent did not allow any deductions for amounts expended or contributed by petitioners for charitable purposes. The parties agree that the receipts generated by petitioners' "instant bingo" activities constitute UBTI under section 511(a). See Julius M. Israel Lodge of B'nai B'rith No. 2113 v. Commissioner, T.C. Memo. 1995-439, affd. 98 F.3d 190 (5th Cir. 1996). Respondent concedes that petitioners are entitled to deductions under sections 162(a) and 512(a) in computing theirPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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