In TAM 201005061, the IRS ruled that a trade association organized in the interest of a specific sport and exempt from taxation under Internal Revenue Code section 501(c)(6) would not lose its exempt status due to a public sale of discount certificates allowing the general public to play at the trade association's sporting facility, but the sales would generate unrelated business income tax.
See also "Income From Sale of Discount Certificates Is Subject to UBIT; Group's Exempt Status Not Jeaopardized," 2010 TNT 25-19, February 8, 2010.
Posted by Jenny Robertson, Associate Editor, Wealth Strategies Journal.
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