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Oil (and similar mineral) production payments sometimes raise the problem of distinguishing between certain kinds of passive investment holdings on the one hand and participation in a business venture on the other. The question arises where an exempt organization holds the right to receive oil or mineral production payments—a fairly common investment for title holding corporations in certain parts of the country. Generally, holding a royalty interest in such property, as opposed to an active working interest, would fall within the IRC 512(b)(2) exclusion from the definition of unrelated business taxable income and would be a permissible source of income. On the other hand, holding a working interest in such property would not fall within the IRC 512(b)(2) exclusion, would be an impermissible source of unrelated business income for an IRC 501(c)(2) title holding corporation, and could result in
revocation of exempt status under the provisions of Reg. 1.501(c)(2)–1(a).
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