Since the 1950s the U.S. federal government has used the loosely defined Unrelated Business Income Tax (UBIT) to tax nonprofit revenue that is not related to an organization’s exempt purposes(Cordes&Weisbrod,1998).Specifically,the IRS defines unrelated business income tax as “income from a trade or business, regularly carried on, that is not substantially related to the performance by the organization of its exempt purpose or function except that the organization needs the profits derived from this activity” (IRS, 2004). State governments that collect corporate income tax have created similar unrelated business income taxes for nonprofits