Question

Pursuant to Code Sec. 512, which tax-exempt organization would have unrelated business taxable income (UBIT)?

All of the above.

The sale of a public radio station's membership list to marketing company.

The sale at a profit of standard legal forms to its members by a local bar association.

The provision of pet boarding and grooming services for the general public by an organization operated for the prevention of cruelty to animals.

Answer 1

d,Pet boarding and grooming services. —The income derived by an exempt organization, organized and operated for the prevention of cruelty to animals, from providing pet boarding and grooming services for the general public is income from unrelated trade or business under IRC 513

trade or business generally means an activity carried on for generating revenue through manufacturing of good or sales of services

specifically 4 heads are excluded from the definition of unrelated trade or business

• valunteer labor
• covenience of members
• donated merchandise
• specific rulings

this comes under public specific rulings