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
OPINION
Fay, Judge:
Respondent determined a deficiency of $12,653.13 in petitioner’s Federal income tax for its fiscal year ending June 30, 1974. After concessions, the only issue is the proper method of allocating certain indirect expenses between petitioner’s exempt and unrelated activities.
All the facts have been stipulated and are found accordingly.
Petitioner Rensselaer Polytechnic Institute, a nonprofit educational organization incorporated under the laws of the State of New York, had its principal office in Troy, N.Y., at the time of filing its petition herein. Petitioner is exempt from…
2Cases cited8 opinions
- Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
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- Browne v. CommissionerUnited States Tax Court · 1980
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- Gino v. CommissionerUnited States Tax Court · 1973
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3Cited by6 opinions
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- Rensselaer Polytechnic Institute v. CommissionerUnited States Tax Court · 1982
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