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Petitioner's line of reasoning has been rejected in an analogous
situation by the United States Court of Appeals for the Eighth
Circuit, the Court of Appeals to which this case would normally
be appealable. In Clarence LaBelle Post No. 217, VFW v. United
States, 580 F.2d 270, 271 (8th Cir. 1978), the taxpayer, a
section 501(c)(4) organization, argued that income from an
unrelated trade or business may be taxed under section 511(a)
only if the trade or business competes with a taxpaying entity.
Since the taxpayer's bingo operation did not compete with
taxpaying entities, the taxpayer argued that it was not subject
to tax. Id. After examining the legislative history of section
513 and the regulations thereunder, the Court of Appeals held
that the tax on unrelated business income is not limited to
income earned by a trade or business whose operations compete
with taxpaying entities. Id. at 274; accord Louisiana Credit
Union League v. United States, 693 F.2d 525, 541-542 (5th Cir.
1982) ("The regulations under section 513 bolster our conclusion
that competition is not essential to the taxability of unrelated
business income."). See also Smith-Dodd Businessman's
Association, Inc. v. Commissioner, 65 T.C. 620, 624 (1975), where
we stated that "unfair competition plays a relatively
insignificant role in the application of the amended unrelated
business tax".
Although section 513(f) legislatively overrides the decision
in Clarence LaBelle Post No. 217, VFW v. United States, supra, by
creating a special exemption for bingo games from the definition
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