The commissions paid to a hospital association by vendors providing debt collection and group purchasing services to its members are subject to unrelated business income tax, the Tax Court has ruled. They are not considered substantially related to the exempt purpose of the association and are not excluded from unrelated business income either as “royalties” or as activities carried on primarily “for the convenience” of its members. The New Jersey Council of Teaching Hospitals is a membership organization whose members consist primarily of 501(c)(3) teaching hospitals and whose board of trustees consists of the organization’s president and the CEOs of the members. It is recognized as a 501(...