Eighth Circuit Reverses Invalidation of Reg in Mayo Clinic Case

Eighth Circuit Reverses Invalidation of Reg in Mayo Clinic Case

U.S. Court of Appeals for the Eighth Circuit

The Eighth Circuit reversed a district court <a href="/lr/resolve//29tcr" rel="noopener" target="_blank">decision</a> that held invalid reg. section 1.170A-9(c)(1) and that held Mayo Clinic is an educational organization under section 170(b)(1)(A)(ii) entitled to the unrelated business income tax exemption, finding that the regulation is valid in part and application of the statute for the years at issue cannot be determined on the summary judgment record.

The Eighth Circuit reversed a district court decision that held invalid reg. section 1.170A-9(c)(1) and that held Mayo Clinic is an educational organization under section 170(b)(1)(A)(ii) entitled to the unrelated business income tax exemption, finding that the regulation is valid in part and application of the statute for the years at issue cannot be determined on the summary judgment record.

The Eighth Circuit reversed a district court decision that held invalid reg. section 1.170A-9(c)(1) and that held Mayo Clinic is an educational organization under section 170(b)(1)(A)(ii) entitled to the unrelated business income tax exemption, finding that the regulation is valid in part and application of the statute for the years at issue cannot be determined on the summary judgment record.

Sec. 170 Charitable, etc., contributions and gifts

Sec. 501 Exemption from tax on corporations, certain trusts, etc.

Sec. 514 Unrelated debt-financed income

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Eighth Circuit Reverses Invalidation of Reg in Mayo Clinic Case