Question

Faith Community Church is exempt from Federal income taxation under § 501(c)(3). To supplement its contribution revenue, it holds bingo games on Saturday nights. It holds all of the licenses and permits required to do so. The net income from the bingo games is $90,000. Of these funds, $60,000 are used to support the ministry of the church. The balance of $30,000 is invested in Faith's endowment fund for church music. Faith Community Church is located in a resort city where bingo games can be conducted by churches, charities, and for-profit entities.

Assume a 21% corporate income tax rate.

b. Calculate the Federal tax liability, if any, associated with the bingo games.

The amount of UBIT associated with the bingo games is $ ____.

Please solve part "B" with explanation. Thank you! [Taxation 2019 Question]

Answer 1

“A common misconception is that gaming is a “charitable” activity. There is nothing inherently charitable about gaming. It is a recreational activity and a business. Although a charity may use the proceeds from gaming to pay expenses associated with its charitable programs, gaming itself does not further exempt purposes. Thus, the sole purpose of a 501(c)(3) organization cannot be to conduct gaming.”

Games of chance like bingo and raffles are often synonymous with tax-exempt organizations. However, the income from such “gaming” activities operated by charities is not automatically tax-free. The IRS has provided more insight into the key rules in this area in its Publication 3079.

So, amount of UBIT associated with the bingo game is $ 71,100.