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statement supports the Trustee’s position here that one of the
four independent sources or components of exempt function income
under section 512(a)(3)(B) is reasonable costs of administration
directly connected with a purpose described in section
512(a)(3)(B)(i) or (ii).
In further support of its position that reasonable costs of
administration directly connected with a purpose described in
section 512(a)(3)(B)(i) or (ii) qualify as one of the four
independent sources or components of exempt function income under
section 512(a)(3)(B), the Trustee relies on the instructions to
Forms 990-T for the years at issue. Those instructions provided
in pertinent part:
Sections 501(c)(7), (9), (17), and (20) organiza-
tions will not be taxed on income set aside for:
1. Religious, charitable, scientific, literary, or
educational purposes, or for the prevention of cruelty
to children or animals;
2. The payment of life, sick, accident, or other
benefits by a section 501(c)(9), (17), or (20) organi-
zation. The amount allowed as a set-aside may not
exceed a limit determined using section 419A. See
sections 419A and 512(a)(3)(E) for details;
3. Reasonable administration costs directly con-
nected with 1 and 2 above.
We acknowledge that the foregoing instructions to Forms 990-
T are not as clearly stated as section 512(a)(3)(B) is. Nonethe-
less, we find those instructions to be consistent with the plain
language of section 512(a)(3)(B). We have held that section
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