City Hospital, a tax-exempt hospital, has purchased a sports and fitness center located about three miles from the hospital. It is a state-of-the-art fitness center that includes an open fitness room with cardiovascular and strength equipment, an indoor track, exercise rooms, racquetball and tennis courts, an aquatic area with two pools, a nutrition center/juice bar, and tanning beds. The hospital's overall goals for the center are to enhance cardiovascular, physical, and psychosocial function, reduce morbidity and mortality, improve quality of life, and promote compliance with a lifelong prevention program.
The membership of the center will consist of three segments of the community:
The general public, employees, and former rehabilitation patients. Each group will be charged a monthly fee and an initiation fee with a reduced fee provided for employees. Within each category, the fees vary depending on the member's age and restrictions
availability of the facilities during specific hours. The hospital hired a professional
consulting firm to conduct a survey of the community to ensure that the fee structured
would achieve its goal of making the center facilities available to an economic cross
section of the community.
You have been contacted by Anne Dexter, the chief financial officer for the hospital
She is concerned that some or perhaps all of the revenue from the sports and fitness
center will be classified as unrelated business income and therefore be subject the
UBIT. Write a letter to Ms. Dexter that contains your findings, and prepare a memo for the tax files. City Hospital's address is 1000 Board Street, Billings, MT 5910l.
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