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512(a)(3)(B) plainly treats non-member income set aside for
reasonable costs of administration directly connected (1) with a
purpose described in section 512(a)(B)(3)(i) as set aside for a
purpose described in that section and (2) with a purpose de-
scribed in section 512(a)(3)(B)(ii) as set aside for a purpose
described in that section.
In any event, we are not bound by the instructions to Forms
990-T for the years at issue. The authoritative sources of tax
law are statutes, regulations, and judicial decisions, and not
informal instructions published by the Internal Revenue Service.
See Casa de La Jolla Park, Inc. v. Commissioner, 94 T.C. 384, 396
(1990). We find the Trustee’s reliance on the instructions to
Forms 990-T for the years at issue to be misplaced.
We hold that section 512(a)(3)(B) treats non-member income
set aside to provide for the payment of reasonable costs of
administration directly connected with a purpose described in
section 512(a)(3)(B)(ii) as non-member income set aside for a
purpose described in section 512(a)(3(B)(ii).
The Trustee’s contentions that section 512(a)(3)(B) identi-
fies four independent sources or components of exempt function
income and that one of those sources or components is reasonable
costs of administration directly connected with a purpose de-
scribed in section 512(a)(3)(B)(i) or (ii) constitute the pre-
mises on which the Trustee constructs its argument that non-
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