Legal Opinion

Rensselaer Polytechnic Institute v. Commissioner

United States Tax Court

Decided December 1, 1982No. Docket No. 7024-79Published

Petitioner is a college exempt from tax under sec. 501(c)(3), I.R.C. 1954. It operates a fieldhouse which is used both to carry on exempt activities and to conduct unrelated trade or business activities. Under sec. 511, I.R.C. 1954, petitioner is subject to tax on the income generated by its unrelated business activities.

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Petitioner is a college exempt from tax under sec. 501(c)(3), I.R.C. 1954. It operates a fieldhouse which is used both to carry on exempt activities and to conduct unrelated trade or business activities. Under sec. 511, I.R.C. 1954, petitioner is subject to tax on the income generated by its unrelated business activities. Held, an allocation of overhead expenses between the two uses which is based on time of actual use is "reasonable" within the meaning of sec. 1.512(a)-1(c), Income Tax Regs.

1Opinion of the Court

Rensselaer Polytechnic Institute, Petitioner v. Commissioner of Internal Revenue, Respondent

Rensselaer Polytechnic Institute v. Commissioner

Docket No. 7024-79

United States Tax Court

79 T.C. 967; 1982 U.S. Tax Ct. LEXIS 11; 79 T.C. No. 60;

December 1, 1982, Filed

Decision will be entered under Rule 155.

Petitioner is a college exempt from tax under sec. 501(c)(3), I.R.C. 1954. It operates a fieldhouse which is used both to carry on exempt activities and to conduct unrelated trade or business activities. Under sec. 511, I.R.C. 1954, petitioner is subject to tax on the income generated by its…

2Cases cited9 opinions

  1. Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
  2. International Artists, Ltd. v. CommissionerUnited States Tax Court · 1970
  3. Browne v. CommissionerUnited States Tax Court · 1980
  4. Bolton v. CommissionerUnited States Tax Court · 1981
  5. Gino v. CommissionerUnited States Tax Court · 1973

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