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          for real property and associated personal property rentals that             
          previously had applied for purposes of determining UBTI.  Tax               
          Reform Act of 1969 (TRA), Pub. L. 91-172, sec. 121(b)(1), 83                
          Stat. 537.  In place of the former exclusion, Congress provided             
          the more limited exclusion now found in section 512(b)(3).  S.              
          Rept. 91-552, at 68-69 (1969), 1969-3 C.B. 423, 468.  In                    
          addition, pursuant to new section 512(b)(4), rents that would be            
          treated as unrelated debt-financed income pursuant to section               
          514(a)(1) were included as UBTI.  TRA sec. 121(b)(2); see also              
          Kern County Elec. Pension Fund v. Commissioner, 96 T.C. 845                 
          (1991), affd. without published opinion 988 F.2d 120 (9th Cir.              
               In the same section of this legislation, Congress amended              
          section 502 to eliminate the former exclusion for rental                    
          activity, replacing it with the more limited exclusion of section           
          502(b)(1), cross-referencing new section 512(b)(3).  TRA sec.               
          121(b)(7), 83 Stat. 542.  Congress also added other special rules           
          in section 502(b)(2) and (3), similarly intended to conform the             
          treatment of exempt organizations’ business activities for                  
          purposes of the UBTI rules and the feeder organization rules                
          under section 502.  Id.; see S. Rept. 91-552, supra at 70, 1969-3           
          C.B. at 469.  Describing this amendment to section 502, the                 
          Senate Finance Committee stated:  “this amendment merely makes              
          these rules [i.e., the UBTI rules and the feeder organization               

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