Does a Non-Profit 501(c)(3) Realize Unrelated Business Taxable Income (UBTI) For Advertising?

Non-profit organizations which are exempt from income tax under 501(a) are subject to tax on unrelated business income. 501(b), 511. Unrelated business income is gross income derived by any organization from any unrelated trade or business, regularly carried on by it, less the deductions allowed. 512. An unrelated trade or business is a trade or business which is not substantially related (aside from the need of such organization for income or funds) to the purpose of the organization. 513. However, unrelated trade or business does not include a trade or business where substantially all the work is performed for the organization without compensation. 513(a)(1). See Rev. Rul. 75-201, 1975-1 CB 164.

The sale of advertising in a publication published by an exempt organization is an unrelated trade or business when the advertising activity is regularly carried on. Reg. 1.512(a)-1(f)(1). See also Rev. Rul. 73-424, 1973-2 CB 190.

Courts have held advertising revenue not to constitute unrelated business income in some circumstances. For example, in National Collegiate Athletic Assn. V. Comm., (1990, CA10) 66 AFTR 2d 90-5602, 914 F.2d 1417, 90-2USTC 50513, revg (1989) 92 TC 456, advertising revenue received by the NCAA from the sale of programs of its annually sponsored championship tournament was not unrelated business income where the tournament lasted less than three weeks and occurred only once a year.

IRS Chief Counsel strongly disagrees with the Tenth circuit. The IRS argues the state court should have taken into account the time spent soliciting the advertisements and preparing the advertising for publication. IRS announced it will continue to litigate the issue in appropriate cases. Action on Decision 1991-015, 7/3/91.

IRS distinguished NCAA where a state university received income from advertising placed in its football souvenir programs. Here, a significant time span was involved over which the activities were conducted. The football season lasted three months and the work in setting up the programs and soliciting adverting took even longer. IRS letter ruling 9137002.

Assuming that the journal is published periodically throughout the year, an exempt organization should not rely on National Collegiate Athletic Assn. The periodic publishing and on going solicitation efforts will likely constitute a unrelated business regularly carried on. See 512.

The court also held advertising revenue does not constitute unrelated business income in US v. American College of Physicians, (1986 S.Ct). In American College of Physicians, the court found that the advertising business contributes importantly to the universitys education program through the training of students.

Also, advertising revenue does not constitute unrelated business income if the advertising contributes to the organizations purpose. For example, publication of legal notices in a bar association journal contributes to the associations exempt purposes by promoting the common interest of the legal profession through providing a single source of information regarding legal events in the county and therefore, wouldnt result in unrelated business income. Rev. Rul. 82-139, 1982-2 CB 108. However, advertising revenue received by a bar association for ads place in its attorney directory are taxable income since the advertising is commercial in nature and represents an effort on the part of advertisers to maximize sales to a certain segment of the public. IRS Letter Ruling 9148054.

Similarly, magazine advertising revenues received by an exempt trucking association did not contribute to the associations exempt purposes where the advertising represented marketing efforts by the advertisers to sell their product. In this case, no systematic effort was made by the organization to advertise products related to the editorial content and no effort was made by the organization to limit advertisements to new products. Florida Trucking Assn Inc. (1986) 87 TC 1039.

It is clear that, with a few exceptions, advertising revenues received by a 501(c)(3) exempt organization will often generate unrelated business taxable income (UBTI).

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Soccer Team Position, Soccer Team Players Position and Set up, 5-4-1 Team Set up

5-4-1,
Defense;

5, defenders,

The addition to this defensive style is a central defender who can control the play from the back line.
This defender could also be an attacking player who will feed through balls to the striker. In addition to this the play maker will help create and initialze an attack from the defensive edge of the mid-field.
It can be thought that this player is also a mid-field player when the attack is mounted.

This team has this formation of positions in order not to lose.
They do not want goals scored against them and are usually willing to have a single goal scored for them and will to play for a draw, albeit 0-0.
It is also possible that their goalkeeper is not the "best" in the league.

It is possible however that this team has also been set up to play a strong attacking team.
This would mean that the coaching staff has done their homework and scouted the opposition.
All in all this team is more prepared to defend as opposed to attack.
This team is an opportunistic attacking team and will usually attack against the run of play.
This happens when the opposing team has made a mistake.

This system and idea can also produce and utilize the positions and concepts known as "wing back".
These are the players who can make over-lapping runs from their defensive ends right to the opposing goal lines.

When communicated properly the following happens.

1) A full on attack has been launched.
At least 5 are attacking simultaneously.

2) The outside midfield has now become support, over lapping and or cutting in and out when and where necessary.

3) Positons have changed to reflect those areas (space) not covered.
The attacking team has changed the zonal aspects and created a player mis-match numerically.

4, mid-fielders are usually arranged as outside left, inside left, inside right and outside right.
The outside players are called, wingers or flank players and are also involved in striking the goal.
This would make this line up have a possibility of 4 strikers at any given time.
These wingers usually have the bulk of the running to do as they could carry the ball from the defending third and into the attacking third.
This also depends on the team strategy as outlined by the coaching staff.

The two inside midfielders are supposed to be the "play makers". These are the individuals who are responsible for carrying out the plans the coach and players have designed and used as the methods of attack and goal scoring.
These positions have traditionally played these roles. However nowadays the play making comes from anyone and sometimes all the players at any given time.
These inside players have also been more defensive in their general on field play.
This defensive idea is to stop the opposition from creating attacking options.

This team will require a midfield who is willing to strike the goal at any given time.
Usualy 2 of these players are latent strikers.
They might feel confident that the defense is solid and willing to step up into the middle third of the field.
They then work in unison with the striker/forward.

This team is usually confident of their lone striker.
The striker in this formation actually acts as a post-up player. This means that this striker usually plays with the opposing defense at his/her back.
This player will try and stretch the defense, will receive the ball to lay it back to the oncoming team-mates to close the ground/space that this striker has created.
The cycle continues until a good scoring opportunity has been formulated.

Occationally this striker will turn and attack the goal when the timing is right.
This is usually communicated to the strikers by their team-mates.
However a great striker will sense these situations based on the run of play and the opportunities that this striker has created.

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