1. “[W]hether income that a tax-exempt charitable organization derives from offering group insurance to its members constitutes ‘unrelated business income’ subject to tax under §§ 511 through 513 of the Internal Revenue Code.” 2. “[W]hether the organization’s members may claim a charitable deduction for the portion of their premium payments that exceeds the actual cost to the organization of providing insurance.”
1. “We hold that ABE’s insurance program is a ‘trade or business’ for purposes of the unrelated business income tax.” 2. “We further hold that the individual taxpayers have not established that any portion of their premium payments to ABE constitutes a charitable contribution.”
