Revenue Ruling 76-296
Internal Revenue Service
1976-2 C.B. 142 (1976)
- Written by Daniel Clark, JD
Facts
A scientific organization contracted to perform research sponsored by a commercial enterprise. Under the contract, the organization agreed to several conditions, including not disclosing data that the enterprise had business reasons for keeping secret, delaying public release of research results until a time at which the release would not jeopardize any of the enterprise’s patent rights, and delaying public release of research results for business reasons unrelated to patent rights. Subject to these agreements, the enterprise paid the organization for the research, the results of which would eventually be made publicly available. The organization requested guidance from the Internal Revenue Service as to whether such research would be treated as carried on in the public interest for the purposes of § 501(c)(3) of the Internal Revenue Code (code).
Rule of Law
Issue
Holding and Reasoning ()
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