District Court Expands Definition of “Educational Organization” in Taxpayer-Favorable Ruling
Author: Katherine E. David, J.D..
Source: Volume 18, Number 06, September/October 2019 , pp.3-4(2)
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Abstract:
A Michigan federal district court recently ruled that the Mayo Clinic is entitled to an $11.5 million refund of unrelated business income tax because it qualifies as an “educational organization” under IRC §170(b)(1)(A)(ii). Although the case arose in the context of a special rule related to unrelated debt-financed income under IRC §514, the analysis could open the door for a private foundation that conducts educational activities to argue that it qualifies as a public charity under IRC §170(b)(1)(A)(ii).Keywords: “Educational Organization” Definition; IRC §170
Affiliations:
1: Strasburger & Price LLP.