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fees) from its list rental transactions were $188,171 and
$243,959, respectively. For 1991 and 1992, petitioner timely
filed Forms 990, Return of Organization Exempt from Income Tax,
and Forms 990-T, Exempt Organization Business Income Tax Return.
Petitioner did not report on either return the income it received
from its mailing list transactions. Rather, petitioner reported
such income as nontaxable royalty and/or related non-trade-or-
business income on Forms 8275, Disclosure Statement, filed as
attachments to its 1991 and 1992 Forms 990-T.
For 1993, petitioner's gross receipts (base price less
commissions, Triplex's running fees, and other miscellaneous
fees) from its list rental transactions were $219,272. For 1993,
petitioner timely filed a Form 990 but did not file a Form 990-T.
OPINION
Section 511(a)(1) imposes the unrelated business income tax
(UBIT) on the unrelated business taxable income (UBTI) of certain
tax-exempt organizations. Section 512 defines UBTI as follows:
SEC. 512. UNRELATED BUSINESS TAXABLE INCOME.
(a) Definition.--For purposes of this title--
(1) General Rule.--Except as otherwise
provided in this subsection, the term "unrelated
business taxable income" means the gross income
derived by any organization from any unrelated
trade or business (as defined in section 513)
regularly carried on by it, less the deductions
allowed by this chapter which are directly
connected with the carrying on of such trade or
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