Exempt Organizations Technical Guide›TG 48: Unrelated Business Income Tax›Table of Contents
B.2. Normal Time Span of Activities
Publication 5894 — Exempt Organizations Technical Guides TG 48: Unrelated Business Income Tax · 2026-10-03 edition · updated 2026-10-04 · United States
(1) Where income producing activities are of a kind normally conducted by
nonexempt commercial organizations on a year-round basis, the conduct of such activities by an exempt organization over a period of only a few weeks doesn’t constitute the regular carrying on of trade or business. For example, the operation of a sandwich stand by a hospital auxiliary for only two weeks at a state fair wouldn’t be the regular conduct of trade or business. See Treas. Reg. 1.513-1(c)(2)(i).
(2) However, the conduct of year-round business activities for one day each week
would constitute the regular carrying on of trade or business. For example, the operation of a commercial parking lot on Saturday of each week year-round would be the regular conduct of trade or business. See Treas. Reg. 1.5131(c)(2)(i).
(3) Where income producing activities are of a kind normally undertaken by
nonexempt commercial organizations only on a seasonal basis, the conduct of these activities by an exempt organization during a significant portion of the season ordinarily constitutes the regular conduct of trade or business. For example, the operation of a track for horse racing for several weeks of a year would be considered the regular conduct of trade or business because it is usual to carry on such trade or business only during a particular season. See Treas. Reg. 1.513-1(c)(2)(i).
(4) The following revenue rulings show how the time span of certain activities affect
whether those activities are viewed as regularly carried on:
a. The sale of advertising during a four-month period by the paid employees
of an exempt organization, which raises funds for an exempt symphony orchestra and publishes a weekly concert program distributed free at the symphony performances over an eight-month period, is a business regularly carried on in determining unrelated income under Section 512. See Rev. Rul. 75-200, 1975-1 C.B.163.
b. However, the sale of advertising by volunteers of an exempt organization,
which raises funds for an exempt symphony orchestra and publishes an annual concert book distributed at the orchestra’s annual charity ball, isn’t a business regularly carried on in determining unrelated income under
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