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Does a Non-Profit 501(c)(3) Realize Unrelated Business Taxable Income (UBTI) For Advertising?




Non-profit organizations which are exempt from income viagra tax under �501(a) are subject to tax on unrelated business income. ��501(b), 511. Unrelated business income is gross income derived order viagra by any organization from any unrelated trade or business, regularly carried on by it, less the deductions allowed. �512. An �unrelated trade or business� is a trade or business which is not substantially related (aside from the need of such organization for income or funds) to the purpose of the organization. �513. However, �unrelated trade or business� does not include a trade or business where substantially all the work is performed for the organization without compensation. �513(a)(1). See Rev. Rul. 75-201, 1975-1 CB 164.

The sale of advertising in a publication published by an exempt organization is an unrelated trade or business when the advertising activity is regularly carried on. Reg. 1.512(a)-1(f)(1). See also Rev. Rul. 73-424, 1973-2 CB 190.

Courts have held advertising revenue not to constitute unrelated business income in some circumstances. For example, in National Collegiate Athletic Assn. V. Comm., (1990, CA10) 66 AFTR 2d 90-5602, 914 F.2d 1417, 90-2USTC 50513, revg (1989) 92 TC 456, advertising revenue received by the NCAA from the sale buy viagra of programs of its annually sponsored championship tournament was not unrelated business income where the tournament lasted less than three weeks and occurred only once a year.

IRS Chief Counsel �strongly disagrees� with the Tenth circuit. The IRS argues the state court should have taken into account the time spent soliciting the advertisements and preparing the advertising for publication. IRS announced it will continue to litigate the issue in appropriate cases. Action on Decision 1991-015, 7/3/91.

IRS distinguished NCAA where a state university received income from advertising placed in its football souvenir programs. Here, a significant time span was involved over which the activities were conducted. The football season lasted three months and the work in setting up the programs and soliciting adverting took even longer. IRS letter ruling 9137002 cheap viagra.

Assuming that the journal is published periodically throughout the year, an exempt organization should not rely on National Collegiate Athletic Assn. The periodic publishing and on going solicitation efforts will likely constitute alternative to viagra a unrelated business regularly carried on. See �512.

The court also held advertising revenue does not constitute unrelated business income in US v. American College of Physicians, (1986 S.Ct). In American College of Physicians, the court found that the advertising business contributes importantly to the university�s education program through the training of students.

Also, advertising revenue does not constitute unrelated business income if the advertising contributes to the organization�s purpose. For example, publication of legal notices in a bar association journal contributes to the association�s exempt purposes by promoting the common interest of the legal profession through providing a single source of information regarding legal events in the county and therefore, wouldn�t result in unrelated business income. Rev. Rul. 82-139, 1982-2 CB 108. However, advertising revenue received by a bar association for ads place in its attorney directory are taxable income since the advertising is commercial in nature and represents an effort on the part of advertisers to maximize sales to a certain segment of the public. IRS Letter Ruling 9148054.

Similarly, magazine advertising revenues received by an exempt trucking association did not contribute to the association�s exempt purposes where the advertising represented marketing efforts by the advertisers to sell generic viagra their product. In this case, no systematic effort was made by the organization to advertise products related to the editorial content and no effort was made by the organization to limit advertisements to new products. Florida Trucking Assn Inc. (1986) 87 TC 1039.

It is clear that, with a few exceptions, advertising revenues received by a 501(c)(3) exempt organization will often generate unrelated business taxable income (UBTI).



The Value of Antique Cuckoo Clocks




As generic viagra cuckoo clocks have been around since 1730 and have always been manufactured by gifted artists and skilled craftsmen, many of the older pieces that have been even minimally cared for are still in existence today. A well-preserved cuckoo clock from the 18th or 19th century can bring a king�s ransom at any of the prestigious auction houses around the world. Bidding can easily get up into the millions for alternative to viagra a certified, pristine Schneider cuckoo clock in perfect working condition. Available in auction houses and high-priced boutiques around the world, antique cuckoo clocks are prized for their hand carved scenes, whimsical displays and attractive facades.

The familiar �cuckoo� sound on the half hour and on the hour never fails to turn heads. There is something about the unique buy viagra call of the cuckoo, a bird that lays her eggs in the nests of cheap viagra other birds and then abandons her young to be raised by others, that hits a harmonious chord in the human psyche. Surely there are better behaved birds to signal the arrival of a new hour, and certainly any number of our aviary friends utter sweeter sounds that could have been employed to usher in that eagerly anticipated lunch hour. For some reason, the cuckoo clock became a worldwide phenomenon during a time when one part of the world was hardly aware of the goings in another.

The cuckoo clock was comparable to the automobile of its era, or the airplane of its time. Any well preserved, functioning example of its humble beginnings is worth a king�s ransom today. Even on Ebay where items are sold as cheaply and quickly as possible, true antiques are order viagra sometimes listed for many thousands of dollars before the bidding is even close to being finished. If you�ve viagra got an antique cuckoo clock, take good acre of it and, should the need arise, it will take good care of you.



Motocross Gear - Worn out of Necessity, Shaped over Time, Finished with Style




When dirt bike racing was in it�s infancy riders wore whatever was available to protect themselves. Open faced helmets, Jofa pants, leather protection� as the protective equipment was not specifically made for dirt bike racing, riders looked more like confused hockey buy viagra playing bikies than dirt bike racers!

As the sport (best sport in the world mind you :) became more popular, the growth was then able to sustain �parallel� or complimentary manufacturing industries. Companies like JT USA, Sinisalo etc. could now focus primarily on making only motocross gear.

More money was now being pushed into research and development of motocross gear, sponsorship of riders and marketing programs

More emphasis was being placed on style so colour was added to gear to match dirt bike colourings or just to be outrageous and different. Pink was big mid eighties (I did not say it was always in good taste).

Body armour moved to be worn over the top of race jerseys therefore they became more stylised to appeal to users. In itself becoming a fashion statement, but was researched and tested to also be practical and offer maximum comfort. Today�s body armour has �floating� shoulder cups as well as flexible back and side panels to cater for both sitting and standing positions when riding. Can come in a range of colour options including clear as well viagra as built in kidney belts on some models.

Race pants received there own special treatment made out of heavy duty nylon with doubled stitching, extra room in the butt to cater for the crouched/sitting riding position as well as cordura, kevlar and leather panels in high wear areas such as the seat and knees. Spandex panels are used to allow for movement where necessary. A quality race pant will offer extra room in the knee area to allow for knee braces that more and more riders are wearing.

Jersey material went from cotton to sweat/moisture wicking polyester/cotton blends to offer greater comfort for prolonged periods of riding. Vented panels were placed in �hot spots� and even little touches like rubber strips in the tail to hold them into the race pants on even the roughest ride.

Boots were being designed to deal with high impact landings and ultimate ankle protection. Replaceable soles and buckles cheap viagra prolonging their use. They are now carefully constructed to avoid the damaging lateral and hyperextension movements around the ankle area.

Dirtbike gloves � choose them wisely and make sure they fit correctly. Some gloves are better suited to certain types of riding than others. Motocross gloves offer better feel for the rider with less padding in the palms. Enduro gloves can be the opposite with more padding to give greater comfort for longer rides.

Elbow protection can be found in a �sleeve� that also covers the forearms. Knee/shin guards are lighter as well as stronger and some hinder �lateral� movement of the knee (gone are the days of using skateboarders protection) generic viagra. Although with the onset of lightweight, composite materials it is possible to have the ultimate alternative to viagra in protection with knee braces.

All this protection would mean nothing if you cannot see. So it is very VERY important to properly protect one of your greatest assets (as well as one of the five senses) in your sight. Different goggle manufacturers have their own registered names for their lenses, but they basically mean the same thing � scratch resistant, shatterproof protection for your eyes.

So next time you go for a dirtbike ride, dress in the latest motocross gear and be comforted in the knowledge order viagra that you have minimized risk to your body as much as possible. That will allow you to focus on what you are there for� enjoying the ride!

The old saying is still as true as ever � �dress for the fall, not for the ride�



Siberia, Russia Part 5 - Khabarovsk and a Little Russian




In this continuing series, we cover my move from San Diego to Chita, Siberia to be a professor at Chita State Technical University. We pick up the story outside the airport in Khabarovsk, Russia.

Khabarovsk

Khabarovsk is an amazing city. Museums with works from Picasso, Rembrandt and other masters. A bustling downtown area with cafes, a lively music scene and architectural triumphs. Then again, maybe not. We were far more interested in finding a hotel with hot water and never ventured into the city.

Outside of the airport, we were a bit flummoxed by the fact there appeared to be no taxis buy viagra. We quickly learned that practically any Russian with a car is also a taxi for hire. After 5 minutes of egging each other on, Grae made taxi arrangements and we were off. Apparently taking in out disheveled appearance after 3 days of traveling, our driver suggested the Intourist hotel. We readily agreed.

During communism, Intourist hotels were set up for exclusive use by foreigners. Ours was fairly nice and, importantly, had showers with copious amounts of order viagra hot water. You can see a picture at http://www.lodging.ru/hotels/intouristkhab.asp. After having returned to humanity with one of the best showers of my life, it was time to brush up on my Russian skills.

I am a huge fan of ice hockey. During the eighties and nineties, many of the best players were Russians. In interviews, they almost always talked about learning English by watching television. If it worked for them, it would work for me. Not exactly.

As Grae showered, I flipped through cheap viagra the eight available channels. Sitcoms were a non-starter, but I eventually found a news channel. I see the images. I know what the images are. I hear the words being spoken by the reporters. I have absolutely generic viagra no idea of what words go with what images. Okay, let�s back up. What words do they use over and over? Damn, do they have to talk so fast? After 30 minutes, I have learned nothing, nada, zippo. My respect for Russians playing in the NHL alternative to viagra has never been higher.

Might as well sleep on it. Yes, day three of the trip was finally done. My original prediction of a 2-day trip was out the window. Still, we were in Russia, so how much longer viagra could it take? Pull out a map and take a look at the country. It is twice the size of the U.S.

Next � When Stairs Attack�



Using Google




Thanks to a unique algorithm that produces most relevant results to any given query, Google has become, indisputably, the best search engine on the Internet. On the last count, Google has indexed over 4 billion pages and tackles around 200 million searches a day! A cluster of 100 thousand servers are used to store, crunch and spew out the query results with lightning speed that you are so accustomed to see.

This phenomenal growth has made Google from a garage startup to an Internet behemoth faster than any company has done before. The prodigies behind this unique search engine, Larry Page and Sergey Brin in the process already got enlisted themselves in billionaire club.

Google is no longer a mere search engine! It is increasingly broadening its offerings to include great new services and excellent tools. Among these services, most notables are News - a news aggregation and searching service, Blogger - an online journal-keeping solution, Froogle - a marketplace for comparison generic viagra shopping, Groups - online discussion groups, Answers - a place to get hard-to-find information for a price, etc.

Google also recently unveiled two more programs. Orkut - a social networking service and Gmail - a free web mail service. Orkut is an online community, where a person can participate in it by invitation from a member only.

If you constantly frown over limited space of your hotmail or Yahoo accounts because they get filled up with junk mails and force you to delete old messages frequently, you will love Gmail with its 1 GB of storage capacity. There are several great features available in Gmail system too. One of them, dubbed as Conversations, allow you to view all exchange mails with somebody, once you select one of the mails. Sorting and searching emails also become much easier with Gmail. The only catch is Gmail displays relevant ads - based on the keywords found in your email - on the right side of the screen when you view an email, much like Google displays ads when you view search results.

Although, Google is constantly adding new and extremely useful features, most of us unfortunately do not use all the capacities of the search engine itself. The following tips will make your Internet browsing more effective if even you are an avid net user.

Choose most specific search words

Google returns web pages that contain all the words in your query. If you would like to see the most relevant pages on the first page of your search result, be very specific with your choice of words. For example: if you would like to research on former NHL hockey player Makarov, you should start your search with Makarov not hockey player order viagra. Even better if you search for the words: hockey player Makarov. Because just the cheap viagra word Makarov will show web pages on "Makarov" a Russian-made handgun and numerous other people and products with the name Makarov. Refining your query in Google means adding more specific words to your initial search. In this example you will hit the right web pages if your search contains: NHL hockey player Makarov.

Sets - a new feature

What if you are looking for a pair of Valentino designer jeans but can't recall the name of the designer? Query on Italian designer jeans may bring you the right result; however, there is a better tool that Google is planning to implement soon, called "Sets".

Fill up the names of some designers that you remember in the given form such as Levis, Wrangler, Versace and click either of the two buttons and voila! You will get a list of designers name and probably, Valentino will be there. But bear in mind that this feature is still viagra at Beta stage.

Calculator

The alternative to viagra other day, I was sitting in a colleague's office. She needed to calculate some basic stuffs and looking for her calculator on her desk. Much to her dismay, she could not find the calculator and started to fumble through her computer programs in her attempt to find Microsoft calculator. I noticed that she was online and the browser was open. I, politely, asked her whether she knew that Google could actually calculate most common mathematical expressions. It came out to be, she did not! She was just amazed after trying it herself. Google is even capable of unit conversion! Give it a try!

Definition

If you are looking for a definition of a particular word or a phrase, Google is the best place to get it. In Google search box, write "define: the word or phrase" without the quotation marks and click search button. If there is a definition available for your search term you will, most certainly, get it. It's a very useful feature for students and people, those who write research papers.

Synonyms

You may think that search engines are too dumb to show query results of the synonyms of your search term. It's not so! At least, in the case of Google! If you use tilde "~" in front of a keyword in your search term, Google will bring results on the synonyms of that word as well.

Searching within a website

Another great feature of Google search engine allows you to make your query within a specific website. First you write your search term in the Google search box and then write "site: the website or domain name". For example: if you are looking for word "Microsoft" within the websitewww.micromedia.com you will write: Microsoft site: micromedia.com.

Check backward links to your website

If you have a website, Google search engine also has a nice feature to show you which web pages are linking to yours. In the search box, write: Link: you website address.

Other important tips to remember are:

There is no need to use "AND". Google always relate all the words in a search term with Boolean "and".

However, if you would like to make your query for two words - one or another - you can use "OR". You have to write "or" in capital letters to give it Boolean value.

Google is not case sensitive. You can write your search terms either in capital or in small letters. You can even mix them up.

Google omits most of the very common words, such as the, in, etc. If you, indeed, need to add a specific word forcefully, use plus (+) sign in front of that particular word. Same way, you can exclude a word from your search expression by putting minus (-) sign in front it.

If you would like to make a search on an exact phrase or expression, put the words within quotation marks. That way, your search result will show only those pages where the exact expression was found. In order to search the phrase: For whom the bell tolls, write "For whom the bell tolls" in the search box. I'll also suggest you to download the Google Toolbar. Apart from the search box and its ability to block pop-ups, Google Toolbar also shows the pagerank of the website you are visiting now. Pagerank is a system of evaluating web pages - developed by Google founders and used as the core of Google's search engine algorithm. The Toolbar also includes feature with the ability to fill up online forms from stored information automatically. You can also keep your daily journal or buy viagra blog right from the toolbar.

Much to net users delight, Google, in accordance with its ambitious mission statement to organize world's information and make it universally useful and accessible, so far doing a great job by providing us the best search engine and extremely handy features and services. We can only hope that the flow of innovative ideas from Google will not slow down in future, when it becomes a public company.



Theory Only; Preventing International Terrorism




Perhaps we should discuss some theory alternative to viagra of exploitation of another mans defense system. The best way to exploit a defense system is to find a whole or weakness. Since the United States viagra knows all our own weaknesses we should find a way to shore up the most critical, yet realize that we do not have to shore up everyone provided we have a contingency or back-up plan in case of attack. Think of a football team with a safety, if the opponent breaks thru the first two lines of defense then your safety picks them up and takes them out.

If the International Terrorists were to believe that there are ten ways to move people, freight and goods, then the disruption of the system(s) of any one, two generic viagra or three makes no difference. So once the system is up and running and it is known to be redundant to such a large degree, then the game is over, we win, since no one would attack knowing our will could be compromised, as the system can repair itself just like the human body. If they take out two refineries buy viagra, we have 1000 more. If they take out power lines, we re-route. If they take out rail lines at a choke point we ship by truck; if they take out a freeway, we re-route immediately. Thus all such targets would be silly. They would not affect our civilization, merely provide more work for Americans to rebuild stronger, thus we are unaffected. We win in advance as they know it is no use at all.

Self-healing distribution channels for power, water, waste, transportation, information, etc are all in place. So by building our civilization strong we also protect our selves from Natural Disaster disruptions as well. No International Terrorist of act of God can defeat us, that seems to be the answer. No weakness without back up. We can beat them if they try or we have already beat them if they don't then onto the next sector to protect. Protecting the Nation becomes a process of elimination of any and all weakness.

Think of it like this. There is no good or evil, as it all just is. But the closest thing to order viagra evil is mediocrity, in difference and weakness. If your remove them from your systems, you do not have to worry about being attacked, because if you are you are strong enough to instantly re-group, get a little pissed off and rage holly hell on your cheap viagra opponent. It is merely a decision of our nation to be in it to win it and not let anything stand between us and goal-line without being totally obliterated. Again without malice or anger, as it is only about one thing; Winning and that means the Protection of the American People and our civilization.



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