Ocean Pines Ass'n v. Commissioner

Affirmed by published opinion. Judge MOTZ wrote the opinion, in which Judge SCHROEDER and Judge CHILDS joined.

OPINION

DIANA GRIBBON MOTZ, Circuit Judge:

The Tax Court determined that the net income from two parking lots and a beach club owned by a tax-exempt association constitutes “unrelated business taxable income.” The association appeals. Because the income derived from the parking lots and beach club is not “substantially related” to the association’s tax-exempt purpose, we affirm.

I

Before the Tax Court, the parties stipulated to the facts. We recite only those facts relevant to the legal…