Rensselaer Polytechnic Institute v. Commissioner
United States Tax Court
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
- Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
- International Artists, Ltd. v. CommissionerUnited States Tax Court · 1970
- Browne v. CommissionerUnited States Tax Court · 1980
- Bolton v. CommissionerUnited States Tax Court · 1981
- Gino v. CommissionerUnited States Tax Court · 1973
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