- 13 - Trustee that that amount of investment income for each year at issue is not subject to that limitation. That position rests upon the contentions of the Trustee that the plain language of section 512(a)(3)(B) identifies four independent sources or components of exempt function income and that one of those sources or components of exempt function income is reasonable costs of administration directly connected with a purpose de- scribed in section 512(a)(3)(B)(i) or (ii). The Trustee posits that the four sources of exempt function income identified by section 512(a)(3)(B) are: (1) amounts paid by members of the association as consideration for goods, facilities, or services; (2) amounts set aside for a charitable purpose; (3) amounts set aside for the payment of life, sick, accident, or other benefits; and (4) reasonable costs of administration directly con- nected with components 2 and 3. According to the Trustee, “It is apparent from the plain language of the statute [section 512(a)(3)(B)] that reasonable costs of administration are an independent basis of Exempt Function Income.” Proceeding from its premises that reasonable costs of administration directly connected with a purpose described in section 512(a)(3)(B)(i) or (ii) are one of the four independent sources or components of exempt function income under section 512(a)(3)(B), the Trustee argues that the limitation in sectionPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011