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Rensselaer Polytechnic Institute v. Commissioner
United States Court of Appeals for the Second Circuit
732 F.2d 1058 (1984)
Rensselaer Polytechnic Institute (RPI) (plaintiff) was a tax-exempt organization. RPI owned a fieldhouse that it used for both exempt purposes and non-exempt purposes, such as commercial ice shows and public ice skating. RPI believed it could deduct from its unrelated business taxable income a portion of the facility’s fixed expenses—such as salaries, depreciation, and maintenance—based on the proportion of overall time the facility was used for such unrelated business activities. The Internal Revenue Service (IRS) (defendant) claimed that RPI could not deduct depreciation expenses for times when the facility was not being used at all because such deductions were not directly connected with RPI’s unrelated business activities as the Internal Revenue Code required. The United States Tax Court found in favor of RPI. The IRS appealed.
Rule of Law
Holding and Reasoning (Pratt, J.)
Dissent (Mansfield, J.)
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