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National Collegiate Athletic Association v. Commissioner
United States Court of Appeals for the Tenth Circuit
914 F.2d 1417 (1990)
The National Collegiate Athletic Association (NCAA) (plaintiff) was a nonprofit, tax-exempt organization established to oversee regional and national collegiate athletic events in all sports. The NCAA men’s basketball tournament lasted for a few weeks every year. The NCAA produced a program with advertisements for each such tournament. For the 1982 tournament, the NCAA received over $55,000 in revenue for this advertising. The Internal Revenue Service (IRS) (defendant) imposed a tax deficiency on the NCAA, finding that this revenue was unrelated business taxable income. The NCAA appealed the ruling in the United States Tax Court. The tax court upheld the IRS’s determination. The NCAA appealed. The NCAA admitted that the advertising was not substantially related to its exempt purpose but argued that it was not regularly carried on by the NCAA.
Rule of Law
Holding and Reasoning (Seymour, J.)
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