In response to a letter ruling request, the IRS ruled in PLR 201701002 that the income to be received by a private operating foundation were related to the organization’s exempt purpose.  Thus, the foundation would not be subject to either the unrelated business income tax nor the excess business holdings tax.

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In TAM 201544025 the IRS decided that a foundation's weekly sales bazaar income is not substantially related to its tax exempt purpose, nor does it qualify for the rental exception for rental of real property under IRC §512(b).