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non-profit organizations which are exempt from income tax under 501(a) are subject to tax on unrelated business income. 501(b), 511. Unrelated business income is gross income derived 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 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.

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 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 universitys education program through the training of students.

Also, advertising revenue does not constitute unrelated business income if the advertising contributes to the organizations purpose. For example, publication of legal notices in a bar association journal contributes to the associations 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, wouldnt 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 associations exempt purposes where the advertising represented marketing efforts by the advertisers to sell 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).

pelican Crushproof Protective Packages - Even a Dinosaur can sit on it!

pelican products are the name for protective packaging and covering that keeps your delicate equipment intact and safe. It is used for cameras, computers, laptops, guns and rifles, flashlights, other sensitive instruments, and any product you consider precious. They are fabricated in an attractive design and the robust cases are made from the finest alloys or similar raw materials. Most of these protective cases are standardized though one can also order for tailor made items that are exclusive to your needs. pelican can thus cater to all your needs of safeguarding those items that you hold dear to heart and wish to cherish for time immemorial!

pelican Guarantees a Lifetime of Protection!

Any manufactured product in this competitive world needs guarantees that stand apart in terms of durability and usage. So is the case with the pelican products, that are known to be the world's toughest protective packages. Its unique product design based on the product it packages assures maximum utility that can be thought synonymous with a live Pelican's large beak that holds so much - and so safely! You can also consider the pelican protective cases as a kind of "time Vault" that shall outlive mankind itself! The quip runs like this - "Pelican protects everything you can think of other than "shark bite" or "bear attack" or "children under 5"! Quite ingenious, don't you think?

A package Protects What You Buy - Like an Insurance Policy!

There is an old saying in the field of packaging - a package sells what it protects - and pelican cases are probably one of the best manifestation of protection combined with a pleasing presentation! They are exquisitely fabricated in designs and colors that enhance the storage or transportation of the products. It is surely like a precious and well integrated insurance policy that will keep your favorite appliance, toys, computer peripherals, sporting arms protected against all odds - well, almost!

Probably there is no end to where and what pelican cases can be used for!

With time and excellent innovations, pelican protective cases have carved out a niche in the markets around the world. Its popularity has evolved many snippets about the usage of pelican protective cases in "near fantasy" usage instances very similar to another odd story about the popularity of a certain tough SUV that had service stations in the most remote areas of the worldeven in a small town under the Mount Everest! The pelican could just be as popular as the most sought after movie star in Hollywood!

I want to discuss Stranglehold. With all the attention going to halo 3, Assassin's Creed, Mass Effect, and madden 2008, Stranglehold is one of those games going under the radar. Stranglehold is a game that is a sequel to the gritty action movie hard Boiled. If anyone has seen the movie hard Boiled, they know that it is an action packed film with amazing gunfire fights.

Stranglehold appears to be no exception to that rule. Chow Yun-Fat reprises his role as inspector Tequila, (no I am not fabricating; that really is his name) and nothing seems to stand in his way from defeating his foes. The demo that came out recently was respectable. In the demo, player will be in control of Tequila as he shoots through the streets of Hong kong. In a nutshell, virtually everything in the movie is available in the game.

For example, slow motion bullet time is incessantly utilized in the game. There are many occurrences where you can jump on a cart and shoot your enemies as the cart rolls towards them. You will also be able to jump on a railing and run/slide down to eradicate opponents. There were some mini-games in the demo that entailed dodging bullets (ala Neo from The Matrix). With a game that has flabbergasting action, the only conspicuous flaw was the camera angles. Midway needs to resolve this problem as soon as possible.

My first reaction when I saw this game was max payne on steroids. If Stranglehold is even half as adequate as max payne, then it is definitely worth playing. Stranglehold is slated for an August release date for the PC and xbox 360 and a September release date for the PlayStation 3.

Do you own a Playstation 3? I Do. And I absolutely love this game machine. In fact, I love it so much that I put my good old trusty Playstation 2 system up for sale and sold it. Mind you, I'm keeping all of my favorite games, because they can be played on the PS3 as well. Especially the two player games that I play often with friends. Thankfully I had several ps2 controllers (4 to be exact) and decided to only sell two of them with my Playstation 2 console. I figured I could use my ps2 controllers on my Playstation 3, and not have to spend another $50.00 on an extra controller.

Now, I did of course know that the Playstation 3 controllers were not the same as the Playstation 2. While they do have their SIXAXIS wireless controllers, they also have SIXAXIS wired Playstation 3 controllers as well. However, these use a usb port in order to be able to plug into the controller ports on the Playstation 3. This did present a problem, because the Playstation 2 controllers do not have a usb plug, but a unique plug that's specific to the ps2 console.

However, having reviewed and written about video games and video game accessories for many years now, and watched as innovative companies designed and developed what are called controller adapters for essentially every single video game console on the market, I was certain that it was only a matter of time before a Playstation 2 to Playstation 3 controller adapter would be released. And boy was I right. Not even 3 months after the release of the Playstation 3, the ps2 to PS3 Controller adapter started showing up on video game web sites.

The Playstation 2 to Playstation 3 controller adapter is an adapter for Playstation 2 controllers. About 3 to 6 feet long, depending on which model you buy. The adapter allows you to plug in a Playstation 2 controller to one and, and then plug the other end, which is a usb plug, into the Playstation 3. Your Playstation 2 controller will work just like any wired Playstation 3 controller, minus the SIXAXIS Support of course, and the HOME button that's on all of the PS3 controllers.

All of the buttons are of course there, so you'll be able to play every single Playstation 3 game just as you would when using a Playstation 3 controller. Unfortunately, though the ps2 controllers have the rumble function / dual shock built in, Sony decided to remove this from the Playstation 3 controllers (and I suspect it had a lot to do with the lawsuit brought against them by the developers of this technology). What this means is that regardless of the DUAL SHOCK functions built into your Playstation 2 controller, unless you're playing Playstation 2 games.

Not only does the ps2 to PS3 controller adapter save you money, and make use of your now unused Playstation 2 controllers, you'll also be able to play your ps2 games just the same as you would on your Playstation 2 console, with all of the rumble and force feedback that would be lacking if you were playing your Playstation 2 games with a Playstation 3 controller.

The controller adapter is a quick and easy way to use your Playstation 2 controllers on your Playstation 3. And above all, it's extremely cheap. priced at under $10.00, it's certainly much cheaper than going out and buying another Playstation 3 controller. In fact, you could buy up to 4 adapters, and make use of all of the Playstation 3 controller ports, and use ps2 controllers in all of them. An excellend, and low cost way to enjoy those multi player games, without having to let your Playstation 2 controllers collect dust.

The first two steps in getting certified in scuba diving is to make sure that you are a reasonably proficient swimmer and you get medical clearance from your doctor to take up the sport. As for the swimming, you dont have to master every type of stroke. Scuba certification only requires that you are able to swim about 200 yards using any stroke you want and to be able to float or tread on water for about 10 minutes. If you are in good general health and are comfortable in the water, then you should be able to scuba dive without any problems.

There are about 1,900 professional scuba dive centers in north america alone and your local ones should definitely be checked out. Most will run basic certification programs on a regular basis. These centers or shops should be listed in the yellow pages and you can also check with websites of some of the major scuba diving certification agencies such as PADI or NAUI as they will also have listings. Sometimes scuba diving courses are offered at universities too.

Make sure that the course you are interested in taking as well as its instructor are certified with one of the major scuba diving training agencies. This will ensure that you get proper, safe training for both the technical background knowledge and practical skills required for certification as a scuba diver. You also want to end up with an internationally recognized certification card if you want to go scuba diving at various locations around the world.

Some vacation resorts offer resort courses lasting a day or two which offer beginners some very basic training in order to try out scuba diving. These are not certification programs. full certification programs involve classroom work, exams, practical skills sessions at a pool and usually about four open water dives in the sea (lake or ocean). The duration of the classroom work and pool sessions vary from a very intensive weekend (with advance reading) to once a week over several weeks. The open water dives will usually take two more days. Dive centers located in the tropics also offer basic certification programs that last several days to a week. Although the intensive weekend programs are quite feasible, many feel that basic scuba diving courses spread out over a few weeks will help beginners learn the skills better. Scuba diving does involve new skills and to learn them all during one full weekend may be too much for some people.

As for which scuba diving certification training agency is the best, there isnt any one recognized organization that is better than another. PADI is the most popular in the world but not necessarily better than NAUI or SSI. NAUI course are often more technical in the classroom than those offered by PADI but both will adequately train you to be a scuba diver. The more important factor would be the individual instructor and your own effort during training/studying. In fact, many scuba diving instructors have certifications from several training agencies.

For people living in the more northern regions, there are a few possible routes to take in order to obtain certification. One can travel down south to the tropics and do the entire basic certification course down there in warm weather. However, this will take up a good portion of a vacation since reading, classroom, pool sessions and open water dives all must be done during that time period. A second option is to take the entire course including the open water dives back in home territory. This usually offers beginners the most time since courses can be spread out over a few weeks. However, the water up north is not as warm as in the tropics and the scuba diving could be seasonal. A third option is to take all the classroom and pool sessions back home and then go down south to do the open water dives in warm waters. Many people have taken this route. Your instructor back home will give you a referral letter to bring down to an instructor located down south who will oversee your open water dives. This is a good combination of taking ample time back home to practice the skills in the pool plus getting the classroom work out of the way followed by having nice warm water to dive in for the open water dives. One thing to be aware of if considering this option is to make sure that your travel to the tropics for your open water dives is not too delayed after finishing up with your pool sessions at home. If too much time has elapsed, one could easily forget the skills learned in the pool by the time a vacation comes along.

The underwater world has so much to offer and only a small percentage of the worlds population will ever have the privilege to see it in person rather than on television. Become one of these individuals who will have the honor of exploring the oceans by getting certified in scuba diving.

Clint Leung is a NAUI certified Master and Rescue Scuba Diver. He is also owner of Free Spirit Activewear http://www.FreeSpiritActivewear.com, an online retailer/designer specializing in premium quality scuba diving activewear. Also numerous articles on scuba diving.

Glenna Jean is a well-respected manufacturer of crib bedding that is available through online retailers and baby specialty stores. The mod Squad bedding collection, first introduced in late 2005, is a good choice for anyone looking for something new and original. mod Squad is a high quality bedding collection with pricing ranging from $300 to $350 for the four-piece set. While certainly on the high end price-wise compared to other national brands of crib bedding, the fabric quality and workmanship of mod Squad bedding more than justifies the price for those who can afford it.

mod Squad comes as a four-piece set which includes a quilt, bumper, crib skirt, and fitted sheet. There is also a five-piece option with your choice of a pillow or diaper stacker available. All pieces are also sold separately. The collection is made from a 60/40 cotton/poly blend and is machine washable. As with most bedding collections, accessories are available to enhance the nursery. two common accessories are not available in the mod Squad pattern, which are a hamper and wall border. However, mod Squad does feature a TV shaped lamp that is both original and adorable.

The mod Squad quilt consists of a genuine patchwork design, which is one of the designators of higher quality craftsmanship. All of the fabrics used in the mod Squad collection are high thread count and superior quality. The quilt is made up of eight squares, two of each of the four fabrics used. The quilt is trimmed by brown velvet, which is also used in the ties of the bumper. Upon close inspection of each of the fabrics, I am pleased that Glenna Jean has used only premium quality fabrics. The quality of the stitching and overall workmanship is very good, as I would expect at this price point.

The bumper measures 9 tall with ties on both the top and bottom. One minor flaw of the bumper is that is in one continuous piece, which makes washing more of a chore. Another feature of the bumper is the patchwork pattern appears on both sides of the bumper. In many cases, the inward facing part of the bumper features the patterns used in the collection, while the outward facing area is a plaid or another striped fabric used as a background. The fitted crib sheet is a cream fleece, which is also on the back of the quilt. The crib skirt has a 15 drop to finish the look of the crib set.

Because mod Squad merchandise is assembled in the United States, it can be particularly appealing for Canadian customers purchasing from a US retailer. It can be shipped to canada duty-free, thereby avoiding charges of 17% or more of the purchase price that apply to bedding manufactured in China or India.

If you like the look of mod Squad, you might want to look at Flashback or Scribbles, all geometric themed crib bedding by Glenna Jean.