Legal Opinion
National Collegiate Athletic Association v. Commissioner of Internal Revenue
Court of Appeals for the Tenth Circuit
Decided September 20, 1990No. 89-9005PublishedCited by 31 opinions
1Opinion of the Court
SEYMOUR, Circuit Judge.
The National Collegiate Athletic Association (NCAA), the petitioner in this case, appeals from the decision of the tax court, which determined a deficiency of $10,395.14 in unrelated business income tax due for the 1981-1982 fiscal year. 1 On appeal, the NCAA challenges the court’s conclusion that revenue received from program advertising constituted unrelated business taxable income under I.R.C. § 512, not excludable from tax as a royalty under section 512(b)(2), I.R.C. § 512(b)(2). We reverse. 2
I
The NCAA is an unincorporated association of more than 880 colleges,…
2Cases cited12 opinions
- Pullman-Standard v. SwintSupreme Court of the United States · 1982
- Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
- Commissioner v. Portland Cement Co. of UtahSupreme Court of the United States · 1981
- Supre v. RickettsCourt of Appeals for the Tenth Circuit · 1986
- United States v. American Bar EndowmentSupreme Court of the United States · 1986
7 more not listed; retrieve them via the Exa API.
3Cited by31 opinions
- Andrea Peckham v. Gem State Mutual Of UtahCourt of Appeals for the Tenth Circuit · 1992
- State Police Association of Massachusetts v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1997
- Estate of F.G. Holl, Deceased and Bank IV Wichita, N.A. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1992
- Arthur C. Hawkins v. Commissioner of Internal Revenue, Glenda R. Hawkins v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1996
- Disabled American Veterans v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1991
26 more not listed; retrieve them via the Exa API.