7
UBTI for amounts paid to outside charities or expended for
charitable purposes as follows:
WMPI:4
Tax Year Ended Deduction
June 30, 1990 $5,965
FSEP:
Tax Year Ended Deduction
Dec. 31, 1989 $1,045
Dec. 31, 1990 5,959
Schoenstatt:
Tax Year Ended Deduction
Sept. 30, 1990 $387
Sept. 30, 1991 755
ACADA:
Tax Year Ended Deduction
Dec. 31, 1989 $5,028
WSA:
Tax Year Ended Deduction
Dec. 31, 1987 $ 2,462
Dec. 31, 1988 7,373
Dec. 31, 1989 13,855
The amounts conceded by respondent include payments made directly
to outside charities and amounts paid from petitioner's general
funds which the parties agree are attributable to "instant bingo"
proceeds. Respondent also concedes that WSA is entitled to
deductions against UBTI under sections 170 and 512(b)(10) in the
4 The parties have stipulated all amounts necessary to compute
WMPI's UBTI for the year ended June 30, 1990. No issue remains
with respect to WMPI.
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