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Losses from Nonmember Activities Could Not Offset UBTI (Losantiville Country Club, CA-6)

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The Tax Court properly determined that a social club could not offset its income from investments with losses from nonmember activities because they were not held for the primary purpose of making a profit. Although the Appeals Court found that the Tax Court misread Portland Golf Club,, SCt., as wholly dependent on demonstrating profitability and […]

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