Women of the Motion Picture Industry, et al. - Page 6

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               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 their               








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